BLM UBBABY
1988
LAN
AMENDMENTS
TO THE CALIFORNIA DESERT CONSERVATION AREA
PLAN OF 1980
Decision
Record
December 1989
California
Desert District
Bureau of Land Management
U.S. Department of the Interior
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United States Department of the Interior
BUREAU OF LAND MANAGEMENT
CALIFORNIA DESERT DISTRICT OFFICE
1695 SPRUCE STREET
RIVERSIDE, CALIFORNIA 92507-2497
IN REPn RKFER lO:
1600
(CA-060.25)
BL^A LIBRARY
SC-324A. BLDG. 50 _
DENVER FEDERAL CENTER
P. 0. BOX 25047
DENVER, CO 80225-0047
Ul
Memorandum
To: State Director (CA-910)
From: District Manager, California Desert
Subject: 1988 Amendment Decision
Enclosed is the Record of Decision for the 1988 amendment review of the California Desert Plan
indicating my approval of the amendments.
The enclosed document is provided for your review and concurrence.
Cj^ jL^uulJL XJ
Enclosure
I cpncur with the California Desert District Manager's amendment decision.
^//:A^^
State Director, California
Date
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RECORD OF DECISION
The 1988 amendment review of the California Desert Conservation Area Plan was conducted in
accordance with Bureau of Land Management Planning Regulations (43 CFR 1610.5-5), with the
procedures set forth in Chapter 7 of the CDCA Plan (1980), and with the Council on
Environmental Quality regulations for implementing the National Environmental Policy Act (40
CFR 1500).
Proposals for amendments were accepted during a 47-day period from January 28 to March 18,
1988. The thirty-three amendments proposed by the public and by the BLM staff were screened
by BLM management and by the California Desert District Advisory Council according to the
following criteria:
1. Is the proposed amendment based upon new data not considered when the plan
was developed?
2. Does the information represent a change in legal or regulatory mandate?
3. Is the supporting detail sufficient and the problem clearly stated so that the request
can be considered?
4. Does the information represent a formal change in State or local government or
agency plans?
A public scoping meeting was held on April 9, 1988 in El Centro, and nineteen proposals were
accepted for consideration in the environmental assessment (EA). Of the remaining fourteen
proposals, seven were rejected from consideration or will be handled by methods more appropriate
than the amendment procedure, as described in Appendix B of the EA. Considerat
ion of seven proposals was deferred until a later date.
The public comment period on the EA extended from June 8 to August 21, 1989. Thirty-two
written comments were received. Oral comments were accepted at the June 16, 1989 meeting of
the Advisory Council in San Bernardino.
The preferred alternative for Amendment Two has been changed from that recommended m the
EA. This amendment, which proposed an ACEC for the area adjacent to Red Rock Canyon, was
rejected on the grounds that designation of an ACERC would not add to the area's current
management and protection. This includes management agreements in which the BLM, the
California Department of Parks and Recreation, the Audubon Society, and the Gear Grinders 4-
WD Club take part.
Amendment 20, a change in range classification of the Pilot Knob grazing allotment, was brought
back from deferred status into the 1988 amendment cycle. This amendment was introduced in the
1983 Plan Amendment cycle but was deferred due to insufficient resource and management
information. It was to be reconsidered after the allotment management plan and environmental
assessment were completed.
The preferred alternatives for all other amendments are the same as those described
in the environmental assessment.
Each amendment is described below. All letters received from the public and responses to specific
comments are given in the Comments and Response section of this Record of Decision.
Finding of No Signiflcant Impact
The environmental assessment identified no significant effects on the human or the natural
environment. Therefore, an environmental impact statement is not required.
CALIFORNIA DESERT CONSERVATION AREA
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1988 PLAN AMENDMENT
INDEX MAP
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Amendment Number
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AMENDMENT ONE
NEW ACEC AT RODMAN MOUNTAINS CULTURAL AREA
Proposed Amendment
Designate an ACEC for cultural resources at the Rodman Mountain Cultural Area.
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment.
Rationale
Rock art sites within this area have been listed on the National Register of Historic Places.
These sites are significant because: they show a diversity of artistic styles and are associated
with habitation sites, trails, and resource exploitation sites; they are conveniently located for
public interpretation; and they are significant to the religious and spiritual concerns of Native
Americans.
ACEC status will provide the mechanism to give this unique area the special management it
needs. Since the ACEC area lies within a recommended wilderness study area, further
protection will be provided if Congress designates this area as wilderness.
Implementation Needs
None
District Manager Date '
/_
] PROPOSED ACEC
I I RODMAN MOUNTAIN
' CULTURAL AREA
AMENDMENT 1
New ACEC
RODMAN MOUNTAINS
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AMENDMENT TWO
NEW ACEC ADJACENT TO RED ROCK CANYON STATE PARK
Proposed Amendment
Designate an ACEC for wildlife and botanical resources adjacent to Red Rock Canyon State Park
in the land co-managed by the BLM and the California State Department of Parks and Recreation.
Other Alternatives Considered
No Action
Decision
Reject Proposed Amendment
Rationale
The area is already adequately protected by a number of management processes. Adding a new
designation would not improve on the area's current management and protection. Further, though
the area is adjacent to a State Park, its resources, in total, do not merit ACEC designation.
Current management includes the following:
1. A Memorandum of Understanding (MOU) between the BLM and the California
Department of Parks and Recreation. The area of the proposed ACEC is managed by
State Parks as part of Red Rock Canyon State Park, except that BLM manages mining
and grazing. The Scenic Cliffs/Nightmare Gulch portion of the area is closed to vehicles
from February 1 to July 1 to protect sensitive resources. From July 1 to January 31,
vehicle use is allowed between the 16th day and the end of each month. Vehicle access
is restricted to three designated routes. State Parks monitors and reports results to BLM.
2. A Cooperative Management Agreement (CMA) between State Parks, BLM and the
Audubon Society. The Audubon Society monitors the Scenic Cliffs/Nightmare Gulch area
and provides an annual report to State Parks and BLM, discussing the trend and conditions
of sensitive resources.
3. A CMA between State Parks, BLM, and the Gear Grinders 4-WD Club. The Gear
Grinders maintain the designated vehicle routes and keep them open for 4-WD use.
Better coordination of these three management efforts is needed. We will hold at least one
annual meeting of the four parties to discuss the results of monitoring, new issues, and
individual concerns. Current management should be evaluated and any needed changes should
be implemented.
Implementation Needs
Annual meeting of BLM, State Parks, Audubon, and Gear Grinders.
District Manager Date
AMENDMENT 2
PROPOSED ACEC BOUNDARY
New ACEC
Red Rock Canyon
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AMENDMENT THREE
NEW ACEC AT DEDECKERA CANYON
Proposed Amendment
Designate an ACEC at Dedeckera Canyon and the adjoining area for botanical and other
significant resources.
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
This canyon is an area of unusual values. Its dolomite cliffs provide habitat for unique plant
assemblages, including Dedeckera eurekensis and many species endemic to the Death Valley
region. Its archaeological sites have yet to receive adequate study, but there is evidence that
they should be protected from degradation. Raptors are present and, possibly, bighorn sheep.
A 4WD route runs through the canyon between Eureka and Saline Valleys. Camping in the
canyon could be hazardous to both the natural resources and to the campers, as flash floods
sometimes sweep down the canyon with great force. ACEC management could protect the
botanical and archaeological resources and control human use of the canyon.
Implementation Needs
None.
District Manager Date
AMENDMENT 3
New ACEC
DEDECKERA CANYON
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PROPOSED ACEC BOUNDARY
10
AMENDMENT FOUR
EXPAND BOUNDARIES OF COYOTE MOUNTAINS ACEC (#62).
Proposed Amendment
Expand boundaries of Coyote Mountains ACEC (#62)
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
The original boundaries of this ACEC included only a few paleontological areas in the Coyote
Mountains. New research by the San Diego Natural History Museum, under cooperative
agreement with the Bureau, has better defined the wider distribution of paleontological
resources.
Implementation Needs
None
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District Manager
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AMENDMENT 4
ORIGINAL BOUNDARY
NEW ACEC BOUNDARY
ACEC 62
COYOTE MOUNTAINS
FOSSIL SITE
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12
AMENDMENT FIVE
DELETE CAMP IRWIN BOUNDARY ACEC (#28)
Proposed Amendment
Delete Camp Irwin Boundary ACEC (#28).
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
Approximately 80% of the ACEC and 100% of the cultural resources are located within the
Fort Irwin National Training Center, which is administered by the Department of the Army.
The cultural resources on public lands under BLM administration do not warrant the special
management provided by an ACEC designation.
Implementation Needs
None
District Manager Date
13
AMENDMENT 5
Delete ACEC 28
CAMP IRWIN MILITARY BOUNDARY
ACEC 28
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AMENDMENT SIX
DELETE KRAMER HILLS ACEC (#38) [
Proposed Amendment
Delete Kramer Hills ACEC (#38).
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
A 100% pedestrian survey of the ACEC in 1984 and again in 1986 failed to locate any cultural
resources within the ACEC. The resources present in this area do not warrant the speciaL
management implied by an ACEC designation.
Implementation Needs
None
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District Manager Date
15
ACEC 38
AMENDMENT 6
Delete ACEC 38
KRAMER HILLS
AMENDMENT SEVEN
DELETE DALE LAKE ACEC (#57)
Proposed Amendment
Delete Dale Lake ACEC (#57)
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
A 100% pedestrian survey of the ACEC in January 1987 failed to locate signifi- cant cultural
resources within the ACEC; previously recorded sites could not be relocated. The resources
present in this area do not warrant the special management implied by an ACEC designation.
Implementation Needs
None
Loi
District Manager Date '
17
AMENDMENT 7
18
AMENDMENT EIGHT
CHANGE CLASS "M" TO CLASS "L" IN YUHA DESERT MANAGEMENT AREA
Proposed Amendment
Change the Multuple-Use Class (MUC) from "M" to "L" in the portion of the Yuha Desert
Management Area between Highways 80 and 98 (excluding the Dunaway Staging Area).
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
Wildlife and cultural resource values in the Yuha Desert have deteriorated steadily since the
late 1970s, in spite of many attempts to achieve management control. These included the
formulation and implementation of the Yuha Desert Management Framework Plan (1975), the
Yuha Basin ACEC Activity Plan (1981), the Yuha Desert Wildlife Habitat Management Plan
(1983), and the Yuha Desert Management Plan (1985). A change to Class "L" would provide
more protective management and would improve the Bureau's potential for halting the decline
of resources in this sensitive area.
Implementation Needs
None
District Manager Date
19
AMENDMENT 8
20
AMENDMENT NINE
CHANGE CLASS "M" TO CLASS "L" IN EAST MESA AREA
Proposed Amendment
Change the MUC from "M" to "L" in the East Mesa Desert between Highway 78 and the
Mexican border, and between the East Highline Canal and the Old Coachella Canal. (Exclude
Long Term Visitor Areas and the Gordons's Well Camp Site).
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
Since adoption of the Desert Plan in 1980, the population of the flat-tailed horned lizard
(FTHL) has declined significantly in some parts of its range in southeast California, southern
Arizona, and portions of Baja California. This decline led to the lizard's being designated as a
"sensitive species" by the BLM and a candidate for listing by the U.S. Fish and Wildlife Service's
Office of Endangered Species and the California Department of Fish And Game. The East
Mesa is one of four crucial habitat areas in California, and the East Mesa ACEC was
designated for protection of the species in 1980. Studies have shown that the crucial habitat
extends west and north of the original boundaries.
Cultural resources along the Lake Cahuilla shoreline extend further to the east than originally
indicated. These resources would also benefit from the added protection provided by changing
the MUC to Class "L".
Implementation Needs
None
District Manager Date
21
AMENDMENT 9
AMENDMENT BOUNDARY
CHANGE CLASS M to L
CLASS M TO L
EAST MESA
22
AMENDMENT TEN
CHANGE CLASS "M" AREAS TO CLASS "L" IN EAST MOJAVE
NATIONAL SCENIC AREA
Proposed Amendment
Change all Class "M" areas within the East Mojave National Scenic Area to Class "L".
Other Alternatives Considered
B. Modify proposal to exclude the Mescal Range.
C. No Action
Decision
Accept Alternative A-(proposed amendment).
Rationale
This action would meet the resource protection objectives of the East Mojave National Scenic
Area Management Plan and would assure effective reclamation of impacts from mining and
recreation use. The change would affect three areas (approximately 120,000 acres) which make
up about 10% of the Scenic Area.
Implementation Needs
None
District Manager Date
23
AMENDMENT 10
EMNSA Boundary
CHANGE FROM M TO L
Alternative A
EAST MOJAVE
NATIONAL SCENIC AREA
Change Class M to Class L
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24
AMENDMENT ELEVEN \
CHANGE MUC FROM "M" TO T AND VEHICLE ACCESS FROM "LIMITED"
TO "OPEN" IN AREA ADJACENT TO DUMONT DUNES OPEN AREA
Proposed Amendment
Change the MUC from "M" to "I" in the area adjacent to the Dumont Dunes Open Area (Area
1); change motorized vehicle access from "limited" to "open"
Other Alternatives Considered
A. Add Area 2.
B. Add Areas 2 and 3 to existing open area. Change Class "M" to Class "I" in Areas 2 and 3.
C. Add Areas 2, 3, and 4 to open area. Change Class "M" to Class "I" in Areas 2, 3, and 4.
D. No Action
Decision
Accept Alternative B.
Rationale
It was originally intended that the Dumont Dunes OHV open area would include subareas 1, 2,
and 3. Maps for the CDCA Plan were drawn incorrectly. This oversight was discovered during
the planning effort for the Dumont area. The amendment will correct this oversight. Addition
of Subarea 2 will incorporate the historically used camping and staging area for the main dunes,
while Subarea 3 will add the area used by families and novice riders.
Implementation Needs
1. Install appropriate boundary markers, including:
Stage 1: Boundary signs, boundary collector routes, and barriers/fencing along Highway
127 and at the north boundary of Salt Creek ACEC.
Stage 2: If Stage 1 items are insufficient add additional barriers/fences at other parts of
the boundary.
2. Provide information/education materials for users, including a brochure, signs, and an
information kiosk.
3. Initiate the designation process for routes of travel in areas adjacent to the open area.
District Manager Date
i
25
AMENDMENT 11
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AMENDMENT TWELVE
CHANGE A PORTION OF IVANPAH DRY LAKE
FROM CLASS "L" TO CLASS "M"
Proposed Amendment
Change the MUC of an area on the north end of Ivanpah Dry Lake, adjacent to Interstate 15
and the Nevada border, from "L" to "M" for construction of an airport.
Other Alternatives Considered
No Action
Decision
Reject Amendment
Rationale
Airport access to a Nevada casino would potentially increase aircraft traffic, necessitating
restricted use of two interstate utility corridors for future transmission lines. The change would
also result in "spot zoning" for a single, non-resident user which is not in accord with the Desert
Plan. There would be impacts on soil and wildlife.
Implementation Needs
None
Lpa
District Manager Date
27
AMENDMENT 12
AMENDMENT THIRTEEN
DELETE A PORTION OF UTILITY CORRIDOR M
Proposed Amendment
Delete a portion of Utility Corridor M.
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
Since the Desert Plan was adopted in 1980, new data has been obtained about significant
wildlife and cultural resources that occur along the ancient shoreline of Lake Cahuilla and
adjacent areas. The County of Imperial has activated a utility corridor along the west side of
the East Highline Canal for use by the Imperial Irrigation District as a route for a 230kv trans-
mission project (Coachella Valley-Niland-El Centro). The cost and timeframe of mitigating the
anticipated impacts of placing a transmission project within Corridor M would contraindicate use
of the corridor as long as an alternative is available.
Implementation Needs
None
District Manager
Date '
29
AMENDMENT 13
^ DEUETE A PORTION OF
UTILITY CORRIDOR M
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30
AMENDMENT FOURTEEN
DELETE A PORTION OF UTILITY CORRIDOR E
Proposed Amendment
Delete a segment of Utility Corridor E (1 mile by 9 miles) within the East Mojave National
Scenic Area.
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
Utility Corridor E currently extends one mile into the Scenic Area along part of the eastern
boundary. This proposal would delete that portion of the corridor, leaving a 2-3 mile-wide
developable corridor. The proposal would conform to objectives of the East Mojave National
Scenic Area Plan for visual resource management and would eliminate constraints imposed by a
wilderness study area in this portion of the East Mojave.
Implementation Needs
None
District Manager Date f
31
AMENDMENT 14
AMENDMENT FIFTEEN
ELIMINATE CONTINGENT CORRIDOR W
Proposed Amendment
Delete Contingent Utility Corridor W
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
The Desert Plan listed this corridor as having potential for future development, but required a
plan amendment to designate it formally as a utility corridor. The East Mojave Plan determined
that such development would not conform to resource management objectives and
recommended that the corridor be eliminated from future consideration.
Implementation Needs
None
District Manager Date
33
AMENDMENT 15
34
AMENDMENT SIXTEEN
CHANGE VEHICLE ACCESS FROM "LIMITED" TO "CLOSED"
IN CHUCKWALLA DUNE THICKET ACEC (#57)
Proposed Amendment
Change motorized vehicle access in the Chuckwalla Dune Thicket ACEC from "limited" to
"closed."
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
The ACEC Management Plan for this ACEC recommended closure of the area of
approximately 2,000 acres for protection of significant and sensitive wildlife values from
inadvertant damage by motorized vehicles.
Implementation Needs
None
_PAu^~<>ulA (^
District Manager
lO
Date
35
AMENDMENT 16
Change Motorized Vehicle Access
from Limited to Closed
ACEC
CHUCKWALLA VALLEY
DUNE THICKET ACEC
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AMENDMENT SEVENTEEN
CHANGE VEHICLE ACCESS FROM "LIMITED " TO
CLOSED" IN THE PALEN DRY LAKE AREA
Proposed Amendment
Change motorized vehicle access in the Palen Dry Lake ACEC from "limited" to "closed."
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
The management plan for this ACEC recommended closure of the area for protection of
cultural resources from motorized vehicle use.
Implementation Needs
None
District Manager Date
37
AMENDMENT 17
PALEN DRY LAKE ACEC
CHANGE MV ACCESS
FROM LIMITED TO CLOSED
\
AMENDMENT EIGHTEEN
PROHIBIT GRAZING SOUTH OF INTERSTATE- 10
IN THE FORD DRY LAKE ALLOTMENT
Proposed Amendment
Prohibit livestock grazing south of Interstate-10 in the Ford Dry Lake Allotment.
Other Alternatives Considered
No Action
Decision
Accept Proposed Amendment
Rationale
Recent loss of the entire population of 50 mountain sheep in the Warner Mountains to
pneumonia as a result of Pasturella hemolvtica infection in combination with known recent
contact with domestic sheep indicates a fatal infection was introduced by domestic sheep to the
mountain sheep. Domestic sheep have also been documented as a source of infection. The
California Department of Fish and Game plans to augment the bighorn sheep population in the
Chuckwalla Mountains but would probably not do so if the Ford Dry Lake Allotment, which is
ephemeral range and grazed intermittently, remains open to domestic sheep grazing.
Implementation Needs
None
District Manager Date
39
AMENDMENT 18
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AMENDMENT NINETEEN
NEW GRAZING ALLOTMENT NEAR DAGGETT
Proposed Amendment
Establish a new ephemeral grazing allotment near Daggett.
Other Alternatives Considered
B. Modify proposal so that Camp Rock Road is the eastern boundary of the
allotment.
C. No Action
Decision
Reject Amendment
Rationale
The proposed allotment is within the range of the Newberry Mountain bighorn sheep herd.
Insufficient information is available on this herd and on the possible effect of domestic sheep.
In addition, the allotment would be within the habitat of the desert tortoise, which was given an
emergency listing as an endangered species by the U.S. Fish and Wildlife Service on August 4,
1989. An additional grazing allotment in tortoise habitat would be inappropriate while this
listing is in effect.
Rejection of the amendment would be consistent with the "1-40 Compromise" of the CDCA
Plan, which designated that all range south of 1-40 be managed to increase the habitat of the
desert bighorn. Accepting the amendment would, in the best case, provide for maintenance of
bighorn habitat, and, in the worst case, could adversely affect the bighorn, themselves. Nothing
in this rejection shall effect on-going trailing authorizations to the extent that sheep skirt the
edge of this range.
District Manager Date
41
/
AMENDMENT 19
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Land Currently
Under Lease
Private Land
Public Land
NEW GRAZING ALLOTMENT
DAGGET
ALLOTMENT BOUNDARY
•••••• Alternative A
— — — — Alternative B
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AMENDMENT 20
PILOT KNOB GRAZING ALLOTMENT CLASS CHANGE
Proposed Amendment
Change range classification of the Pilot Knob grazing allotment from ephemeral to
ephemeral/perennial.
Alternatives Considered
A- Allow year-round grazing (refer to environmental assessment).
B. Allow use from March to October.
C. No action.
Decision
Accept Alternative A with modification. Change range classification to perennial.
Rationale
As requested in the Record of Decision for the 1983 CDCA Plan Amendments, the Ridgecrest
Resource Area completed the Pilot Knob Allotment Management Plan (AMP) and an
environmental assessment (EA) of its proposed actions. The AMP and EA have been reviewed
by the public. The Bureau has consulted with the U.S. Fish and Wildlife Service (USFWS)
about the effect of implementation of the AMP on the desert tortoise, which was designated an
endangered species under an emergency listing on August 4, 1989.
When implemented, the AMP will institute specific actions to reduce conflicts between cattle
grazing and tortoises. Fences and other facilities will be constructed so that cattle can be
moved to areas outside of tortoise habitat during the periods when tortoises are active and
feeding. Cattle will be allowed inside tortoise habitat only when tortoises are inactive and
underground. These actions will improve and stablize perennial plant vigor by controlling
livestock distribution throughout the allotment.
Implemenation Needs
Construct fences, pipelines, and a well.
Since part of the allotment is within Wilderness Study Area 173 (recommended as non-
suitable), preference will not be granted until after Congress decides on wilderness status. Until
that time, AUMs will be allocated on a temporary non-renewable basis.
43
Supplemental Information
This amendment was introduced in the 1983 Plan Amendment cycle. However, due to
insufficient resource and management information at that time, the decision to accept the
amendment was deferred until completion of the allotment management plan and environmental
assessment.
District Manaeer Date /
44
AMENDMENT 20
45
COMMENTS & RESPONSES
WRITTEN COMMENTS AND RESPONSES
The BLM received a total of 32 letters addressing the proposed amendments during the public
comment period. All letters were reviewed. Those letters that had substantive comments (i.e.,
questions or issues that had a direct bearing on a proposed amendment) were given a response.
Table 1 lists each comment letter in order of receipt and designates a reference number. Within
the letter the substantive remarks are noted and the response is keyed to the appropriate comment.
All comment letters have been reprinted verbatim and substantive comments addressed. Letters
that did not address substantive issues but presented an opinion are acknowledged by their
inclusion.
TABLE I
COMMENT LETTERS
Letter
Number Source of Letter
1 Beverly Childs Mcintosh, Riverside County Planning Dept.
2 H.G. Wilshire, Mountain View, CA
3 Peter Burk, Citizens for Mojave National Park, Inc.
4 Dale A Musegades, U.S Border Patrol
5a Pete Bontadelli, CA. Department Fish and Game
5b Dennis J. O'Bryant, CA Division of Mines and Geology
6 Mary Ann Henry, Ridgecrest
7 Richard Spotts, Defenders of Wildlife
8 Edward Karapetian, Dept. of Water & Power, City of L.A.
9 Fred Simon, Kern County Planning & Development, Bakersfield
10 Robert D. Johnstone, U.S. Air Force, Edwards Air Force Base
49
TABLE I (CONT.)
11 Donald W. Moore, Audubon Society, Yuma Chapter
12 Edwin L. Rothfuss, Death Valley National Monument
13 Brooks Harper, U.S. Fish & Wildlife Service, Laguna Niguel
14 Elizabeth Forgey, Boron, CA
15 John R. Swanson, Minneapolis, MN
16 Vincent Yoder, CA Native Plant Society, Bristlecone Chapter
17 Jay B. Wilson, California Woolgrowers Association
18 Donald W. Moore, Audubon Society, Kerncrest Chapter
19 William E. Rinne, U.S.D.I., Bureau of Reclamation
20 Emery Henrich, Mojave, CA
21 Kenneth B. Jones, CA Dept. Parks & Recreation, San Diego
22 Jeffery J. Tunnell, Gear Grinders Four Wheel Drive Club
23 Cary W. Meister, Audubon Society, Yuma Chapter
24 Elden Hughes, Whittier, CA
25 Mary L. Grimsley, Ridgecrest, CA
26 Jerry D. Grimsley, Ridgecrest, CA
27 Elden Hughes, Whittier, CA
28 Judith Anderson, Sierra Club - So. Cal. Reg'l. Conserv. Comm.22
29. Patrice Davison, CA Assn. 4- WD Clubs
30. Hi Desert Multiple Use Coalition, Ridgecrest
31. Wayne Rettig, Ridgecrest
32. Suzanne Shettler, CA Native Plant Soc, Carmel Valley, CA
50
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CA.
BCM:if897
July 6, 19B9
={iVE^^iDc COURlV
PLAnninc DEPA^umEnu
Gerald E. Hillier, District Nanager
California Desert District
Burea'-i of Land Management
1695 Spruce Street
Riverside, CA 92507
Dear Mr . Hi 1 1 i er :
i--'^iiii\:\Tr']ti:
1
i
.--i
lA
4-
..-vdniinj_
ACTION BY:
nerURN TO.
Thank you for transmitting to us the Environmental Assessment for
the 1993 Proposed Plan Amendments to the California Desert
Conservation Area Plan of 1980.
Staff has reviewed the three amendments that address areas in
Riverside County. These proposed amendments, numbers 16, 17 and
13 will provide increased protection to i>jildlife habitat and
cultural resources.
Staff concurs with the Bureau of Land Management ( BLM ) amendment
proposals for ACEC No. 57, Chuc(-:awa 1 1 a Dune Thicket, ACEC No. 55,
Pal en Dry Lake and the Ford Dry Lake Allotment.
Please continue to inform this Department of BLM actions
affecting Riverside County.
Very truly yours,
RIVERSIDE COUNTY PLANNING DEPARTMENT
Roger S. Streeter, Planning Director
BCM:pa
4080 LEMON STREET, 9^" FLOOR
RIVERSIDE, CALIFORNIA 92501
(714)787-6181
51
46-209 OASIS STREET, ROOM 304
INDIO, CALIFORNIA 92201
(619)342-8277
-4.
California Desert District F=Vi:V- '^-. Ci
Bureau of Land Management
ATTN: Plan Amendments
1695 Spruce St.
Riverside, CA 92507
Dear Sirs,
.333 JUL 13 ^H 2^ 52 July 9, 198Q
I favor Alternative A for Amendments 1-4, 8-10, and 13-18; Alternative B for
Amendments 7 and 12; Alternative D for Amendment 11, and Alternative C for
Amendment 19.
If, as indicated for Amendment 11, "manageable boundaries" is the principal
criterion for expanding Dumont Dunes ORV Open Area, it would seem to me that
2-1 complete closure of the area would go even farther toward accomplishing that
end.
Sincerely,
H.G. Wilshire
1348 Isabelle Ave.
Mtn. View, CA 94040
52
Response to H. G. Wilshire
Response to 2-1
In 1973, the Interim Critical Management Program for Recreation Vehicle Use on the California
Desert established the Dumont Dunes Open Area, based on historical recreational use. In 1980,
the Desert Plan continued that designation. Because of the popularity and longtime use of this
area, closure of the dunes without adequate environmental grounds would be unfair to many
recreationists and could result in difficulties in enforcing the closure.
53
( gg Ep, oo3 \
CITIZENS FOR MOJAVE NATIONAL PARK, INC.
P.O. BOX 106 BARSTOW. CALIFORNIA 92312
ESTABLISHED 1976
California Desert District O
Bureau of Land tlanagement ^3
ATTN: Plan Amendments
1695 Spruce Street
Riverside, CA 92507
Dear Mr. Hillier; 21 June 1989
Thank you for sending us a copy of the the proposed 1988 plan amendments to the Desert Plan.
Below are our comments on the Proposed 1988 Amendments to the CDCA EA.
We support Alternative A of Plan Amendment *10. All Class fl areas in EMNSA should be
redesignated Class L. It is contradictory that National Scenic Area lands should be anything less than
Class L. All the areas, including the Mescal & Ivanpah mountains merit Class L status due to their
wildlife, scenic, botanic and cultural values.
We are opposed to Plan Amendment * 12. We support Alternative B~reject the amendment.
We see no need for an airport on Ivanpah Dry Lake. Our public lands do not exist for Whiskey Pete's
Casino's profits. If Whiskey Pete's wants to build an airport, let them build it on private land in Nevada.
The proposed airport would be a nuisance, add noise pollution, and be a visual disaster to the wonders
of East Mojave National Scenic Area. The proposed airport lies in and near crucial desert tortoise
habitat and the proposed airport would decimate tortoise populations in the area.
We support Alternative A of Plan Amendment *\A. By deleting a segment of Utility Corridor E
within the southeast corner of EMNSA , visual and scenic resources will be preserved. The utility
corridor will still exist but will be moved outside EMNSA. slightly to the east. By eliminating this
segment of the utility corridor, the Signal Hill WSA can be better protected and managed.
We support Alternative A of Plan Amendment 'IS. By deleting Contingent Utility Corridor W. a
great amount of EMNSA's scenic quality will not be threatened. New transmission corridors are not
appropriate in a National Scenic Area.
Outside the EMNSA area, we are opposed to plan amendment *19. We support Alternative C to
reject the amendment to establish a new ephemeral grazing allotment near Daggett. We want to see
bighorn sheep protected from the diseases of domestic sheep and cattle.
Thank you for your consideration of our responses. We believe that "Take Pride in America'
means managing our public lands to protect natural and cultural resources.
Sincerel
Peter Burk
erel^ /?
, President
54
\ <sq ^A c>c^ [
^m2\ ?^2^^5
U. S. BORDER PATROL
Iiuniigraiion &.Saturali:,anon Service
1111 North imperial Avenue
Post Office Box 60
El Centro, California 92244
C"lir. -L--^^ DISTRICT
Office of I he Chief Patrol A gem
June 20, 1989
Mr. Gerald Hillier, District Manager
California Desert District
Bureau of Land Management
1695 Spruce Street
Riverside, California 92507
Dear Mr. Hillier:
ELC 40/92-C
K
S^£S_l j
.\il\'
y
^:-^
4-1
We received a copy of the Proposed 1988 Plan Amendments for the California
Desert Conservation Area and noted a couple of proposals which trouble
us.
Proposal numbers 8 and 9 involve changing the multiple class use from
"M" to "L". We have no objections to the change as it affects the general
public. However, our responsibility for patrolling the International
Boundary should warrant a specific exemption. Illegal alien and drug
traffickers cannot be given free reign because of restrictions which could
potentially limit our ability to carry out our congressional mandate.
We would like to go on record as opposing the change in class from "M"
to "L" unless we can be given assurances that it would not limit our
operations.
Thank you for the opportunity to provide comments on this issue.
1/
Sincerely,
Dale A. Musegades ^
Chief Patrol Agent
55
Response to U. S. Border Patrol
Response to 4-1
The proposed change in multiple-use classification from "M" to "L" is based on new information
and is intended to enable BLM to better manage the wildlife and cultural resources present in the
Yuha Desert and the East Mesa areas. Congress has mandated the protection of severely declining
species such as the flat-tailed horned lizard which occurs in these areas.
The change will not affect vehicle use on existing roads. In order to protect sensitive resources,
the Bureau allows cross-country travel only where it is absolutely necessary; e.g., law enforcement
and life-threatening situations. We plan to continue our program of mutual cooperation with the
U.S. Border Patrol.
56
•tate rrf Qlaltf0mta (^^HH.
GEORGE DEUKMEJIAN
GOVERNOR
GOVERNOR'S OFFICE
OFFICE OF PLANNING AND RESEARCH
1400 TENTH STREET
SACRAMENTO 95814
(9] 6) 323-7 4H0
DATE: July 13, 1989
TO; U. S. Bureau of Land Management
California Desert District
ATTN: Irene Rice
1695 Spruce Street
Riverside, CA 92507
FROM; Office of Planning and Research
State Clearinghouse
RE; Environmental Assessment, Proposed Plan Amendments to the California
Desert Conservation Area, Plan of 1980 (SCH 89061602)
As the designated California Single Point of Contact, pursuant to Executive
Order 1237?, the Office of Planning and Research transmits attached corrments
as the State Process Recommendation.
This recommendation is a consensus; no opposing comments have been received.
Initiation of the "accommodate or explain" response by your agency is,
therefore, in effect.
Sincerelv .
Robert P. Martrnez
Director
Attachment
cc: Applicant
57
^^eAOo^
Resources Building
1416 Ninth Street
95814
(916) 445-5656
TDD (916) 324-0804
California Conservation Corps
Department of Boating and Waterways
Department of Conservation
Department of Fisfi and Game
Department of Forestry
Department of Parks and Recreation
Department of Water Resources
GEORGE DEUKMEJIAN
GOVERNOR OF
CALIFORNIA
THE RESOURCES AGENCY OF CALIFORNIA
SACRAMENTO, CALIFORNIA
Air Resources Board
California Coastal Commission
California Tahoe Conservancy
California Waste Management
Board
Colorado River Board
Energy Resources Conservation
And Development Commission
San Francisco Bay Conservation
and Development Commission
State Coastal Conservancy
State Lands Division
State Reclamation Board
State Water Resources Control
Board
Regional Water Quality
Control Boards
U. S, Bureau of Land Management
California Desert District
ATTN: Irene Rice
1695 Spruce Street
Riverside, CA 92507
Dear Ms, Rice:
July 13, 1989
The State has reviewed the Environmental Assessment, Proposed Plan Amendments
to the California Desert Conservation Area, Plan of 1980, submitted through the
Office of Planning and Research.
We coordinated review of this document with the California Highway Patrol,
State Lands Commission, Lahontan and Colorado River Regional Water Quality
Control Boards, Colorado River Board, and the Departmens of Conservation,
Fish and Game, Parks and Recreation, and Transportation.
The Departments of Fish and Game, and Conservation have provided the attached
comments for your consideration.
Thank you for providing an opportunity to review this document.
Sincerely,
for Lordon F. Snow, Ph.D
Assistant Secretary for Resources
Attachments
cc: Office of Planning and Research
1400 Tenth Street
Sacramento, CA 95814
(SCH 89061602)
State of California
Memorandum
SseAoos
The Resources Agency
^° '■ The Honorable Gordon K. Van Vleck
Secretary for Resources
1416 Ninth Street
Sacramento, CA 95814
Attention Gordon F. Snow, Ph.D.
Projects Coordinator
From Department of Fish and Game
Date
July 7, 1989
5a
Subject: Proposed 1988 Plan Amendments to the California Desert
Conservation Area, Bureau of Land Management (BLM), SCH 89061602
The Department of Fish and Game has reviewed the Draft
Environmental Assessment (EA) for the proposed 1988 amendments to
the California Desert Plan. The EA describes the environmental
effects of accepting or rejecting each of the 19 proposed
amendments accepted by the ELM for review. We have the following
comments on the proposed amendments:
Amendment 3, Designate an Area of Critical Environmental Concern
(ACEC) at Dedeckera Canyon and the Adjoining Area for Botanical
and Other Significant Resources.
We support adoption of the proposed amendment.
Amendment 5, Delete ACEC No. 28, Camp Irwin Boundary.
We support adoption of the proposed amendment.
Amendment 6, Delete ACEC No. 38, Kramer Hills.
We support adoption of the proposed amendment.
Amendment 8, Change the Multiple Use Class from "M" (Moderate) to
"L" (Low) in the Portion of the Yuha Desert Management Area
between Highways 80 and 98 (Excluding the Dunaway Staging Area).
We support adoption of the proposed amendment.
Amendment 9, Change the Multiple Use Class from "M" to "L" in the
East Mesa Desert between Highway 78 and the Mexican Border, tEe
East Highline and the Old Coachella Canals (Excluding Long-Term
Visitor Areas and the Gordons's Well Camp Site).
We support adoption of the proposed amendment.
Amendment 10, Change all Class "M" Areas within the East Mojave
National Scenic Area to Class "L".
We support adoption of the proposed amendment.
59
"29 cA ooS
The Honorable Gordon K. Van Vleck -2-
July 1, 1989
5a- 1
Amendment 11, Change the Multiple Use Class from "M" to "I"
(Intensive) in the Area Adjacent to the Dumont Dunes "Open Area";
Change Motorized Vehicle Access from "Limited" to "Open".
We support adoption of the preferred alternative (adoption of
Alternative B; add areas 2 and 3) provided that boundary fences
are established between areas 2 and 3 and the Salt Creek Hills and
Salt Creek ACEC. Off highway vehicle activity is currently
impacting the west side of the Salt Creek Hills.
Amendment
12,
Change
the
Multi
pie
Use Class
of
an Area
I on
the
North
End
of
Ivanpah
Dry
Lake ,
Adj
acent to
Inte
rstate
15
and the
Nevada
Border
, from '
'L"
to "M"
for
Construction
of an
Air
port.
We support adoption of the preferred alternative to reject the
proposed amendment. The placement of an airport in this area
could negatively impact the Ivanpah Desert Tortoise Crucial
Habitat Area through cumulative impacts to the tortoise caused by
increased traffic and development within the region of the
ai rport .
Amendment 15, Delete Contingent Utility Corridor W.
We support adoption of Alternative A.
Amendment 16, Change Motorized Vehicle Access in the Chuckawalla
Dune Thicket ACEC from "Limited" to "Closed".
We support adoption of Alternative A. Motorized vehicle access
into this area is an inappropriate use.
Amendment 17, Change Motorized Vehicle Access in the Palen Dry
Lake ACEC from "Limited" to "Closed".
We support adoption of Alternative A. Motorized vehicle use
in this area is an inappropriate use.
Amendment 18, Prohibit Livestock Grazing South of Interstate 10 in
the Ford Dry Lake Allotment"!
We support adoption of Alternative A. The Department has
previously recommended the elimination of livestock grazing in the
area due to the potential of spreading disease to bighorn sheep
from contact with domestic sheep. Potential negative impacts to
the desert tortoise caused by the grazing use within its habitat
is another major consideration in our support of this alternative.
Amendment 19, Establish a New Ephemeral Grazing Allotment near
Dagget.
We support the selection of adopting Alternative C to reject this
amendment .
60
"^SEA oos
The Honorable Gordon K. Van Vleck -3-
July 1, 1989
Thank you for the opportunity to review and comment on the EA.
you have any questions, please contact Fred Worthley, Regional
Manager of Region 5, at 330 Golden Shore, Suite 50, Long Beach,
CA 90802 or by telephone at (213) 590-5113.
If
Pete Bontadelli
Director
61
Response to California Department of Fish and Game
Response to 5a- 1
The Dumont Dunes Management Plan will indicate a tiered set of management actions to deal
with encroachments into areas surrounding the OHV area. Signing routes closed and monitoring
is the first step. If signing is not effective, the next step will be fencing. The Salt Creek Hills
ACEC Management Plan has been amended to include a fence on the northern boundary of the
ACEC near the Little Dunes. Construction is scheduled for 1990.
62
Stat? of California
Memorandum
SS fcA COS-
THE RESOURCES AGENCY OF CALIFORNIA
To
From
Dr. Gordon F. Snow
Assistant Secretary for Resources
Ms. Irene Rice
U. S. Bureau of Land Management
1695 Spruce Street
Riverside, California 92507
Department of Conservation — Office of the Director
Dote
Subject:
5b
July 10, 1989
Environmental
Assessment for the
Proposed 1988 Plan
Amendments to the
California Desert
Plan, SCH# 89061602
5b-1
The Department of Conservation's Division of Mines and Geology
(DMG) has reviewed the Environmental Assessment (EA) for the
Proposed 1988 Plan Amendments to the California Desert Plan, and
we offer the following comments for consideration.
Amendment 3
The proposed Dedeckera Canyon Area of Critical Environmental
Concern (ACEC) includes areas where the potential for economic
industrial minerals has been recognized by DMG's Mineral Land
Classification Program. DMG's work in this area (Taylor and
Joseph, 1988) has determined that portions of the proposed ACEC
are underlain by carbonate and siliceous rocks that elsewhere
have comprised economic resources of limestone and silica. We
recommend that consideration be given to the mineral potential of
this area before adopting this ACEC.
If you have any questions concerning these comments, please
contact Zoe McCrea, Division of Mines and Geology Environmental
Review Officer, at (916) 322-2562.
Dennis J. O' Bryant
Environmental Program Coordinator
DJO:TM:efh
cc: Zoe McCrea, Division of Mines and Geology
Timothy McCrink, Division of Mines and Geology
Reference;
Taylor, G. C. , and Joseph, S. E. , 1988, Mineral Land Classifi-
cation of the Eureka-Saline Valley Area, Inyo and Mono Counties,
California: California Division of Mines and Geology Open-File
Report 88-2.
63
Response to California Division of Mines and Geology
Response to 5b- 1
Cliff wall and talus slopes within the upper portions of the canyon are composed of Paleozoic age
carbonate and siliceous rocks (Department of Conservation, Division of Mines and Geology, 1988,
Mineral Land Classification of the Eureka-Saline Valley Area, Inyo and Mono Counties, California,
Open File Report 88-2, geologic map). These rocks, due to lack of interest in the area, distance
to markets, and environmental restrictions in the area existing at this time, are recognized as having
a low potential for development. This potential was considered in the review of the purpose of
the ACEC. While the ACEC does not segregate the area from entry under the United States
mineral laws, it is recognized that measures placed in operating plans, or modification of operating
plans to protect natural and cultural resources in accordance with the prescriptions in the ACEC
plan may limit access to these minerals. These tradeoffs are part of our consideration in the
development and implementation of the ACEC plan.
64
I 'SB EA oa(c \
389 JUL 25 ?■« 35 U
CaH-^fTalaCA Desert District
Bureau of Land Management
ATT: Plan Amendments
1695 Spruce St.
Riverside. California 9250?
329 Perdew
Ridgecrest, CA 93555
July 23, 1989
6-1
I have studied the I988 Plan Amendments to the Calif. Desert
Conservation Area Plan of 1980 and wish to make the following
comments:
Amendments #1 to #7: I support ALL of the changes in ACEC designa-
tions.
Amendments 8, 9, 10: I support changing Class M areas to ClassL
in the Yuha Desert Management Area , the East Mesa Area and East
Mojave Scenic Area,
I oppose Amendment #11 to Class change at Dumont Dunes, ORVs do
not need any more areas to rip-up and exclude non-vehicle oriented
recreationists, ORVs drift into the Amargosa riparian area,
and we do not need any more of that.
I oppose Amendment #12 to have an airport on Ivanpah Dry Lake
and to change the Class from L to M. Create an airport for a
casino because they do not want to drive cars. Too bad I
I support #16 and 17 changing Class L to Closed the Chuckwalla
Dune Thicket ACEC vehicle access and Palen Dry Lake ACEC vehicle
access,
I support #18 to prohibit grazing south of Interstate 10 on the
Ford Dry Lake Allotment.
I am oiH>e-&»d to #19, to establish a new ephemeral allotment near
Daggett. No more cattle or sheep allotments on the desert.
Mary ^nn Henry
T
65
Response to Mary Ann Henry
Response to 6-1
The riparian habitat of the Amargosa River is within the Amargosa ACEC (#13) and begins
approximately 4 miles north of the OHV area. Any problems will be resolved by signing, fencing,
and ranger patrol.
See also response to 2-1.
66
--." ''f*- T
OF WILDEff^l'B >^H 3: I
L_^l_..^_n:i..,-..;.:/ . J
o
I* !
\JA
J i
"""1 "!
U]\- _;
i 1
__] ;
t i
July 22. 1989 "''TTT'^^ [iiSZjlM.
Gerald E. Hillier, District Manager
California Desert District mm
U.S. Bureau of Land Management /
ATTN: Plan Amendments
1695 Spruce Street ! r .'.■:?-', vj;
Riverside, CA 92507 !.-....-.^-—
Re: Response to Environmental Assessment for the Proposed 1988
Amendments to the California Desert Conservation Area Plan.
Dear Mr. Hillier:
Defenders of Wildlife submits this letter as our comments and
recommendations on the above-referenced document. Please consider
our input, and include this letter in the appropriate public record
At the outset, we generally support and applaud BLM' s Preferred
Alternatives for those proposed amendments relating to important
wildlife habitats (with the exception of Amendment #11) .
Specifically, we endorse and urge BLM to adopt the Preferred
Alternatives for Amendments #2, 3, 8, 9, 10, 12, 13, 14, 15, 16,
17, 18, and 19. We concur with the described justifications for
BLM's Preferred Alternatives on these Amendments. Indeed, we wish
to commend BLM for these positive Preferred Alternatives.
For example, we are especially pleased with BLM's Preferred
Alternative to adopt Amendment #18. This Amendment would prohibit
livestock grazing south of Interstate 10 in the Ford Dry Lake
Allotment. Defenders had submitted a requested desert plan
amendment identical to this Amendment #18. We are grateful that
BLM has now -considered this Amendment, and is apparently inclined
to implement it. We hope this Amendment will be adopted and
implemented as soon as possible.
On the other hand, we are disappointed that BLM's Preferred
Alternative on Amendment #11 is to expand the "open area" avail-
able for off -highway vehicle recreation in the Dumont Dunes. We
disagree with BLM, and we instead recommend Alternative D to
reject this Amendment.
From an endangered species conservation perspective, we believe
that BLM has prudently accepted as its Preferred Alternative the
CALIFORNIA OFFICE: 5604 ROSEDALE WAY, SACRAMENTO, CALIFORNIA 95822 • (916) 442-6386
NATIONAL OFFICE: 1244 NINETEENTH STREET, NW • WASHINGTON, DC 20036 • (202) 659-9510
67
SS^A ooT
OF WILDLIFE
2.
adoption of Amendments #8 and #9. Implementation of these Amend-
ments would improve protection for the flat- tailed homed lizard,
Defenders of Wildlife is greatly concerned at the continuing
decline of this species and its habitats. Consequently, we are
pleased that BLM is willing to take steps to increase its conser-
vation. We hope these Amendments #8 and #9 will be adopted soon,
Thank you very much for considering our views.
Sincerely,
^
' ■ . ■ /
Richard Spotts
California Representative
Defenders of Wildlife
RS/js
cc: Interested parties
68
(s^e^f^oog
Depgintoeinit of Water and
■:^y.' ^9r, •^^':
" ' , -:•> '
TOM BRADLBY
Maj'or
e City of Los Angeles
Commission
RICK J CARUSO, President
JACK W LEENEY, Vue President
ANGEL M ECHEVARRIA
CAROL WHEELER
WALTER A ZELMAN
JUDITH K DAVISON. Secretary
Mr. Gerald E. Hillier
District Manager
California Desert District
Bureau of Land Management
1695 Spruce Street
Riverside, California 92507
Dear Mr. Hillier:
NORMAN E. NICHOLS. General Manager and Chief Engirieirr. r
ELDON A COTTON, Assistant General Manager- Power \..'.\::
DUANE L GEORGESON, Assistant General Manager ■ Wafer ' . ;,; '
DANIEL W WATERS. Assistant General Manager ■ External Affair's™ '
NORMAN J POWERS. CW/fmanr/a/O/I/Jfff ! :'' •
July 25, 1 ^;8|^_^;;r^j ;^
8 r-:S''=:::-
t
Los Angeles Department of Water and Power (DWP)
Comments on Proposed 1988 Plan Amendments to the
California Desert Conservation Area Plan of
1980 - Environmental Assessment
8-1
We have reviewed the proposed Environmental Assessment
and have the following comments concerning Amendment 12 and
Amendment 15:
Amendment 12 would change the Multiple-Use Class
designation of an area on Ivanpah Dry Lake from Class "L" to
Class "M" to allow for the construction of an airport. DWP is
opposed to this amendment.
The proposed airport lies in an area currently
designated for utility corridors in the California Desert
Conservation Area Plan (Desert Plan) . Corridor D and Corridor BB
come together in this area forming a corridor up to five miles
wide which .is, ^crucial to the electric energy supply of the Los
Angeles Basin. Currently, DWP has four transmission lines (TLs)
in Corridor D and a right-of-way for a TL in Corridor BB. We also
believe that additional TLs will be needed in the future to meet
increasing electrical energy demand in Southern California.
The proposed airport and its safety zone will make it
more difficult to site future TLs and will restrict the potential
use of the existing interstate utility corridors. Because of its
proximity to existing and future TLs, the airport would endanger
lives, aircraft, and TLs. The proximity of the airport to DWP TLs
will be detrimental to the reliability of the DWP electrical
"^system as part of the western states' electrical network.
69
1 1 1 North Hope Street, Los Angeles, California D Mailing address: Box II I, Los Angeles 90051-0100
Telephone: (2\'ii)A%\-A2\\ Cable address: dewapola f/4A'. (213) 481-8701
g?z£"/A ooS
Mr. Gerald E. Hillier - 2 - July 25, 1989
I DWP agrees with the Bureau of Land Management's (BLM)
recommended preferred alternative to reject the adoption of
Amendment 12 and further concurs with the cited rationale in
support of this recommendation.
8-1
8-2
If Amendment 12 were to be adopted, DWP believes that
the airport should be relocated at least 3/4 of a mile northwest
of the current proposed location and the runway reoriented to
parallel existing corridors and transmission lines. The
relocation would help to minimize potential conflicts between
I low- level flying aircraft and the transmission lines.
Amendment 15 would delete contingent Corridor W from
the Desert Plan. Contingent Corridor W, along with other utility
planning corridors, was identified in the planning process for the
Desert Plan by the Joint Utility Advisory Committee in the late
1970s "to establish a network of joint-use planning corridors
capable of meeting projected utility needs to the year 2000."
Further, this utility corridor element will serve as a guide for
future decision making, beyond the year 2000,
The elimination of contingent Corridor W will further
limit possible energy transmission routes through the California
Desert for utility companies. Corridor BE and Corridor D will
continue to be important transmission routes for DWP as well as
other utility companies for future transmission projects, but
the elimination of contingent Corridor W may contribute to the
congestion of these two utility corridors. We feel that the time
is approaching for BLM to reexamine the existing corridor
network within the California Desert. We would be available to
work with the BLM in this effort.
If you have any questions regarding our comments or
would like to meet with our staff, please contact Mr. George P. Nino
at (213) 481-4047.
Sincerely,
EDWARD KARAPETIAN
Manager of Environmental and
Governmental Affairs
c: Mr. Richard Fagan, Manager
Needles Resource Area
101 West Spikes Road
Needles, California 92363
Mr. George P. Nino
70
Response to Los Angeles Department of Water and Power
Response to 8-1
We are essentially in agreement concerning Amendment 12 and thank you for the additional
information and suggestion for possible relocation of the airstrip. Due to other factors, we could
not consider that alternative location.
Response to 8-2
Your comments on Proposed Amendment 15 are well taken. When Contingent Corridor W was
identified, it was to officially recognize that location as a potential corridor. With that designation,
it would still have been necessary to amend the CDCA Plan in order to activate the corridor.
Removing the designation will encourage utility companies to seek transmission routes outside the
East Mojave Scenic Area. However, if it should become necessary to use this route in the future,
an amendment to the CDCA Plan could be proposed.
71
I'gg^/? oo^
RANDALL L. ABBOTT ^- — • 2700 M Street
DIRECTOR Suite 100
^ . , „ . „, Bakersfield.CA 93301
David Pnce 111
Assistant Director (805) 861-2615
DEPARTMENT OF
PLANNING AND DEVELOPMENT SERVICES
July 21, 1989
9 ^.^
California Desert District j ; ^
Bureau of Lard Management , ' '"'"
Attention Plan Amendments *'\^
1695 Spruce Street ;•;:::
Riverside, CA 92507 " o ;:: :::?.
• ._ '^ J — -
— i
Re: Environmental Assessment, Proposed 1988 Amendments to the California Desert
Conservation Area Plan 3-
Ladies and Gentlemen:
Thank you for the opportunity to comment upon the above-noted project. One of
the proposed Areas of Critical Environmental Concern (ACEC) is located in Kern
County: the Red Rock Canyon ACEC. We concur in the analysis presented and have
no further comments at this time.
Very truly yours,
RANDALIx L. ABBOTT, Director
Plapmng\and Development Services
~i'i
sib
72
DEPARTMENT OF THE AIR FORCE
HEACHl^fteS^ iflfctORCE FLIGHT TEST CENTER (AFSC)
Qf,Qfi9)WA'R05 AIR fOUCi l&tSi, CALIFORNIA 93523
S83 JUL 2B ?M Z 56
ml
Gerald E. Hi I I ler
California Desert District
Bureau of Land Management
ATTN: Plan Amendments
1695 Spruce Street
Riverside, CA 92507
Dear Mr . H i II i er :
» 4 JUL itef
^?'^77m^
10
h
iiV
10-1
Thank you for the opportunity to review the Envir
for the Proposed 1988 Plan Amendments to the Calif
Area Plan of 1980. Two amendments, specif icall
Critical Environmental Concern (ACEC) Adjacent t
three (ACEC at Dedeckera Canyon) are located unde
Both areas may experience military aircraft overfl
above ground level. The Air Force Flight Test Ce
Air Force Base assumes since no impacts to airspa
the EA, that no overflight restrictions are be i n
ACECs. If restrictions may be considered now or i
ble adverse impacts to military airspace use must
onmental Assessment (EA)
ornia Desert Conservation
y numbers two (Area of
0 Red Rock Canyon) and
r special use airspace,
ights as low as 200 feet
nter (AFFTC) at Edwards
ce use were addressed in
g considered for these
n the future, the poss i -
be included in this EA.
If you have any questions regarding the above comment, please contact Wendy
Waiwood, of my staff, at (805) 277-3837.
S I ncer e I y
ROBERT D. JOlHNSTONE
Chief, Plans and Policies Division
73
Response to U. S. Department of the Air Force
Response to 10-1
The Bureau recognizes that mihtary aircraft training and testing activities in the California Desert
are an important part of the national defense system of the United States. Overflights of military
aircraft at low levels over the proposed ACECs are expected. ACEC designation will not affect
this activity.
74
Kemcrest Chapt^
- ' U r ; <
National Audubon Societv
■ \
.'LJT'f.G _ I
i'O: DA'
P.O. Box 984 m Jul 2" TM 2- 5o \M...J U-
Ridgecrest, CA 93556 - VRJCT 11
11-1
.„. .1
flA'SMi
July 25, 1989
California Desert District i .' "
Bureau of Land Management f ■•1 '
1695 Spruce St. i ' ,.::::; .".^v" '
Riverside CA 92507 U^'n;;^.. ^0:_
Attn: Plan Amendments
Re: 1988 Plan Amendments
Dear Mr. Hillier,
We are opposed to Amendment #6 Kramer Hill ACEC being deleted. We believe that
area to be proposed Category 1 tortoise habitat, crucial habitat. It also does
not make sense to remove semi -protected desert habitat in view of the crisis
tortoises are in. The area becomes a "lost resource". The Federal Emergency
Listing yesterday should make you pause and reconsider. Under "Environmental
Consequences" you do not list wildlife, perhaps because under "Affected
Environment" you note that a pedestrian survey found "no other resources of
special management concern", meaning no tortoises. We would like to be sure of
that - that no tortoises were found in an area where they almost certainly are
found in. We understand that there may be a heap leach mine planned for the
area and deletion of the ACEC will aid that.
We support your other proposed actions of "support" or "reject" except for
Amendment #11 which we oppose.
We are pleased to see Amendment #2, which we proposed, being supported.
Thank you for the opportunity to comment.
Sincerely,
Donald W. Moore, President
cc: Desert Tortoise Preserve Committee
Sierra Club
.-.1
75
Response to Kerncrest Chapter, National Audubon Society
Response to 11-1
The Kramer Hills ACEC is located in an area which has been proposed as Category I desert
tortoise habitat. The tortoise was given an emergency listing as an endangered species on August
4, 1989. It will be protected as required by the Endangered Species Act. Deletion of the ACEC
designation will not affect management of the tortoise in this or any other area. A mine operator
will be subject to the requirements of the Endangered Species Act for operations on public lands.
A plan of operations has been filed for heap leaching within the area, but so far there has been
no activity on public lands. ACEC status would not affect the process, if mining should occur.
See also responses to 14-4 and 28-7.
76
United S|;pEt€5^ D^epkrtment of the Interior^
IN REPLY REFER TO:
L7619
^ NATIONAL PARK SERVICE
JM^J^ ^#^LK^ Sa^&NAL monument
"' DEATH VALLEY, CALIFORNIA 92328
July 25, 1989
Gerald E. Hillier, District Manager
California Desert District
Bureau of Land Management
ATTN: Plan Amendments
1695 Spruce Street
Riverside, California 92507
12
• "A-
;i;:'i5/:.^-.|f"
m
12-1
12-2
Dear Gerry:
The staff of Death Valley National Monument has reviewed the
Proposed 1988 Plan Amendments to the CDCA Plan of 1980. Overall,
the amendments appear to be environmentally beneficial. However,
we are concerned over the proposal to enlarge the vehicle play
area at the Dumont Dunes due to the potential for affecting the
resources of Death Valley National Monument.
The environmental assessment for Amendment 11, the expansion of
the Dumont Dunes Open area through changes in the Multiple Use
Class, appears to- be deficient in that the potential impacts to
Death Valley National Monument are not identified. Expansion of
the area open for vehicle play will, in our opinion, result in
significant increased visitation and vehicle play in the area.
This, in turn, will further tax the ability of local emergency
medical services to respond to accidents. The enlarged vehicle
play area will make effective law enforcement and visitor
assistance patrols mere difficult because the perimeter will be
much greater.
There is a likelihood that expansion of the vehicle play area and
increased visitor use will result in increases in the generation
of dust. This, in turn, may impact the scenic quality of the
region during certain weather conditions. We suggest that
additional evaluation be done on the potential for impacts due to
increased dust generation, especially to the scenic quality
within Death Valley National Monument and the adjacent Wilderness
Study Areas .
jProtection of the Amargosa River is of utmost importance. As you
Yknow, this river flows through the Dumont area and into Death
77
^^^/lO(2
12-3
J^Valley National Monument. Within the Monument the Amargosa River
supports a significant population of Amargosa River Pupfish
(Cyprinodon nevadensis amargosae ) . We believe there is a strong
probability that OHV use will spill over into Area 4 and degrade
the Amargosa River within the Dumont Dunes area, and those
impacts may extend into the Monument and adversely impact the
habitat of the pupfish through degraded water quality. We assume
that the only effective method of keeping OHV use out of this
sensitive area is fencing. Are there any data on the occurrence
of unlimited OHV use outside the boundary of the existing open
area?
12-4
12-5
12-6
It is difficult to comprehend that impacts to archaeological
resources over such a large area can be adequately mitigated.
To do so would require a complete survey of the entire area
proposed to be open to unlimited OHV use. The proximity of Salt
Creek, the Amargosa River and Saratoga Spring causes us to
believe there would is a high probability that significant
_archaeological resources exist throughout the area.
The environmental assessment does not address potential impacts'
to the two species of dune beetles known to inhabit the area^
Has additional study of their distribution been made since th^
work of Andrews and Hardy in 197 6? Expansion of OHV use in the
area seems questionable if these two beetles are endemic and are
already experiencing impacts due to the existing OHV use.
Perhaps additional work on the significance of these two species
of beetles is in order before the environmental assessment can be
completed.
We believe some OHV use in the Dumont area "spills" over into
Death Valley National Monument, especially in the Saratoga Spring
and Ibex areas. We would like to work with the BLM staff in the
Barstow Resource Area Office in controlling any such illegal use
through a public education program using signs and patrolling
rangers .
Thank you for the opportunity to comment on the environmental
assessment for the 1988 CDCA Plan Amendments. If you have any
questions please contact us.
Sincerely,
^
Edwin L. Rothufu:
Superintendent
78
Response to National Park Service, Death Valley National Monument
Response to 12-1
It is not anticipated that enlargement of the OHV area will adversely affect Death Valley National
Monument. The draft Dumont Dunes Management Plan includes education of the OHV public
concerning street legal use of vehicles within the Monument. The plan also calls for additional
BLM and volunteer personnel to provide visitor services.
Response to 12-2
The only dust generated in the area is along the access road. Dust abatement measures proposed
in the Management Plan should prevent any increase in dust.
Response to 12-3
See responses to 5a-l, 6-1, and 13-1.
Response to 12-4
Areas 2 and 3 are mostly devoid of cultural sites. However, there is a small area which may
contain cultural resources. It will be surveyed along with the Tonopah and Tidewater Railroad
grade and its associated town sites (Sperry, Dumont, and Valjean). The survey will determine
the area's eligibility for inclusion in the National Register of Historic Places. A mitigation package
will be prepared for eligible sites, followed by consultation with the State Historic Preservation
Officer, as required by Section 106 of the National Historic Preservation Act. Mitigation will be
accomplished through data recovery.
See also response to 5a- 1.
Response to 12-5
The Bureau's legal mandate is to conserve listed threatened or endangered species. No such
species exists in the Dumont Dunes area. References to unclassified species of beetles (Hardy
and Andrews, 1976) are preliminary and incomplete. The lone report did not address other nearby
dune areas (only six of 40 in California were visited) nor was sampling intensity stated. If these
beetles do constitute endangered species, the California Department of Fish and Game and the
U.S. Fish and Wildlife Service are the appropriate agencies to initiate a formal listing process.
The BLM will cooperate with such actions by allowing research to be conducted. In the interim,
other nearby dune systems are protected through either closure to OHVs (Kelso and Ibex) or
OHV use on limited or existing trails (Devil's Playground and Cadiz).
79
Response to Death Valley National Monument (cont.)
Response to 12-6
Use of existing routes outside the OHV area is legal. If a specific problem is identified, signing
and fencing of the Monument boundary and patrols by BLM and National Park Service (NPS)
rangers will be considered. A cooperative agreement between BLM and the NPS could be
prepared for handling any problems which may arise.
80
United States Department of the Interior
FISH AND WILDLIFE SERVICE
LAGUNA NIGUEL FIELD OFFICE
24000 Avila Road
Laguna Niguel , California 92656
iji Reply Refer To:
FWS/LNFO (1-6-89-TA-944)
13
] iM
July 26, 1989
MEMORANDUM
To:
From:
Subject :
District Manager, California Desert District, Bureau of
Land Management, Riverside, California
Acting Field Supervisor
Proposed 1988 Plan Amendments to the California Desert
Conservation Area, California
The Fish and Wildlife Service (Service) has reviewed the
environmental assessment for the proposed 1988 Plan Amendments to
the California Desert Conservation Area. The proposed amendments
include the creation of three new Areas of Critical Environmental
Concern (ACEC), deletion of three existing ACECs, one boundary
adjustment to an ACEC, five multiple use class changes, deletion
of portions of three utility corridors, three changes in
motorized vehicle access, and two changes in the Livestock
Grazing Element. Under the Bureau of Land Management's (Bureau)
preferred alternative, 17 amendments would be accepted and two
would be rejected.
The Service offers the following comments on those amendments
which we believe have potential the affect fish and wildlife
resources :
Amendment 2. New ACEC Adjacent to Red Rock Canyon. The Service
concurs with the Bureau's assessment that this proposed amendment
will provide additional protection to nesting and foraging
raptors and to numerous Federal candidate species, such as the
desert tortoise ( Xerobates agassizii ) , Mohave ground squirrel
( Spermophilus mohavensis ) , and Red Rock tarweed ( Hemizonia
arida ) . Therefore, the Service supports the adoption of this
amendment .
Amendment 3. New ACEC at Dedeckera Canyon. ACEC designation in
this area would lead to increased protection for desert bighorn
sheep (Ovis canadensis nelsoni ) and the Federal candidate
species, July gold ( Dedeckera eurekensis ) , as well as other plant
13-1
gg£5^0(3
District Manager 2
species endemic to the Death Valley region. The Service supports
adoption of this amendment.
Amendment 8. Change Class "M" to Class "L" m the Yuha Desert
Management Area. This amendment has been proposed in response to
deteriorating habitat values for the flat-tailed horned lizard
( Phrynosoma meal 1 ii ) , which is a category 1 candidate for listing
under the Federal Endangered Species Act (Federal Register
54:559; January 6, 1989). The change to Class L would permit the
Bureau to place greater environmental constraints on mining, off-
road vehicle use, and other activities which could occur in this
region and allow for management actions which would benefit the
conservation of the flat-tailed horned lizard. For these
reasons, the Service supports the adoption of Amendment 8.
Amendment 9. Change Class "M" to Class "L" in the East Mesa
Area. The Service supports adoption of this measure for the same
reasons advanced for Amendment 8.
Amendment 10. Change Class "M" Areas to Class "L" in East Mojave
National Scenic Area. This proposed amendment would increase the
Bureau's ability to manage wildlife on approximately 120,000
acres within the East Mojave National Scenic Area. Included
among the resources found in this area are numerous species of
raptors, desert tortoises, bighorn sheep, mule deer (Odocoileus
hemionus ) , and four candidate species of plants. Alternative B
would exclude the Mescal Range area from the land use
classification change and result in fragmentation of wildlife
habitat management actions. Therefore, the Service recommends
that Alternative A, which would involve the land use change on
the entire 120,000 acre area, be adopted by the Bureau.
Amendment 11. Change Class "M" to Class "I" and Vehicle Access
from "Limited" to "Open" in Areas Adjacent to Dumont Dune Open
Area. Alternatives A, B, and C would add varying amounts of land
to the Dumont Dunes Open Area in an effort to "acknowledge
historic use patterns and . . . provide manageable boundaries for
the open a^rea," as stated on page 4-12 of the environmental
assessment. Alternative A would set a Wilderness Study Area as a
boundary for off-road vehicle use, while Alternatives B and C
would allow use of areas near and at the Salt Creek ACEC and the
Amargosa River, respectively.
The environmental assessment identifies several wildlife species
of concern in the area of the proposed expansions. Two Bureau
sensitive fish species, the Amargosa pupfish ( Cyprinodon
nevadensis amargosae ) and the Amargosa speckled dace (Rhinichthys
osculus nevadensis ) , are known to occur upstream from the Open
Area, while the Dumont Dunes support two new, unclassified, and
potentially endemic species of beetles, Eucilinus sp. and
^ Tr igonoscuta sp. Despite the fact that these wildlife
82
13-2
13-3
S'^ ie/^oi3
District Manager 3
resources occur within or near the proposed expansion areas,
there is no discussion of the potential impacts of Alternatives A
and B in the Environmental Consequences section of the
assessment . Furthermore, the environmental assessment does not
contain any information on means by which impacts to Wilderness
Study Area 222 would be prevented. Although the Service is not
mandated to evaluate the impacts of projects to wilderness areas
per se, the management of these areas in a manner that excludes
many activities that are detrimental to wildlife can provide
numerous benefits to many species. Therefore, we are concerned
about the resulting impacts should off-road activity be permitted
to the borders of a Wilderness Study Area. The Service believes
that potential adverse impacts to wildlife habitat within
Wilderness Study Areas 219, 220, and 221 can also result from
adoption of this amendment. Although these areas have been
recommended as nonsuitable for wilderness, they are currently
being managed under the Interim Management Policy and Guidelines
for Lands under Wilderness Review to retain their wilderness
values .
The rationale given for expanding this particular Open Area may
create or perpetuate a management strategy that results in a
spiral ing downward trend of loss of habitat. Legalization of the
unauthorized activity that has had an impact on wildlife
resources will not solve this problem. Although this amendment
may not increase the overall use of the Open Area, it will
legitimize currently occurring dispersed recreation. A potential
outcome of this type of management would be continued spread of
the illegal activities to areas outside of the proposed
boundaries .
13-4
Finally,
thorough
endemic
could be
the beet
extirpat
indicate
and does
strategy
manageme
the environmental assessment should provide a more
analysis of the impacts that could occur to the two
beetles and the native fish species and of means that
used to avoid these impacts. With particular regard to
les, permitting any actions which could result in the
ion of species prior to their scientific descriptions
s a iack of sensitivity to these natural resource values
little towards contributing towards a true multiple use
that maintains a balanced approach to resource
nt .
Amendment 12. Change a Portion of Ivanpah Dry Lake from Class "L"
to Class "M" . As the environmental assessment indicates, Ivanpah
Dry Lake is surrounded by Category 1 desert tortoise habitat and
development of an airport and its ancillary features would very
likely lead to degradation of this habitat. Therefore, the
Service concurs with the Bureau's recommendation that this
amendment be rejected.
83
SEE A 0(3
13-5
District Manager
Amendment 13. Delete portion of Utility Corridor M . The
Environmental Consequences section of the environmental
assessment indicates that adoption of this amendment may have a
minor impact on the Yuma clapper rail (Ral lus longirostris
yumanensis ) , a federally listed endangered species. We are
unable to determine from the document how the rail might be
affected, as the proposed amendment is to remove the utility
corridor from potential rail habitat. However, Section 7 of the
Federal Endangered Species Act requires that all Federal agencies
consult with the Service, either formally or informally, should
any action undertaken by that agency have the potential to affect
a listed species. Therefore, we recommend that the Bureau
contact the Service with regard to this amendment to ensure
compliance with the Endangered Species Act.
Amendment 14. Delete One-mile Wide and Nine-mile Long Segment of
Utility Corridor E. The Service recommends the adoption of this
amendment, which would remove the potential of utility
construction within 5,760 acres of Category 1 tortoise habitat in
the East Mojave National Scenic Area.
Amendment 15. Eliminate "Contingent" Corridor W. The Service
also recommends adoption of this amendment because of benefits to
the desert tortoise within the East Mojave National Scenic Area.
Amendment 16. Change Motorized Vehicle Access from "Limited" to
"Closed" in Chuckwalla Dune Thicket ACEC. The Chuckwalla Dune
Thicket is dominated by large palo verdes ( Cercidium f loridium)
and ironwoods (Olneya tesota ) and provides important habitat for
numerous species of wildlife, including many migratory birds.
Eliminating vehicle access through this area will benefit these
species. Therefore, the Service concurs with the Bureau's
recommendation that this amendment should be adopted.
Amendment 18. Prohibit Grazing South of Interstate 10 in the
Ford Dry Lake Allotment. The Service recommends adoption of this
amendment which will enhance opportunities to manage bighorn
sheep in the'Pord Dry Lake area.
Amendment 19. New Ephemeral Grazing Allotment near Daggett.
Adoption of this amendment would adversely affect bighorn sheep
through potential disease transmission and competition for
forage, while the desert tortoise would be affected by
competition for the annual plant species upon which it feeds.
The Service recommends against adoption of this amendment for
these reasons.
In conclusion, the Service commends the Bureau for presenting a
set of amendments which, on the whole, will enhance wildlife
values in the California desert. We support the Bureau's
recommendations on those amendments which could affect wildlife
with the exception of Amendment 11, the Dumont Dunes proposal.
84
%'€^A 0/3
District Manager 5
Additionally, we urge the Bureau to fully consider its
responsibilities under Section 7 of the Endangered Species Act
which requires all Federal agencies to consult with the Service
if a federally funded, permitted, licensed, or constructed
project could affect a listed species. Given the current
situation with the desert tortoise, we recommend that the Bureau
fully consider the tortoise in its planning activities in the
event this species is listed in the near future.
If you have any questions concerning these comments, please
contact Ray Bransfield of my staff at FTS 796-4270 or (714) 643-
4270.
Sincerely ,
Brooks Harper
Acting Field Supervisor
85
Response to U. S. Fish and Response to U. S. Fish and Wildlife Service
Response to 13-1
The Amargosa River is an intermittent water way through the Dumont Dunes OHV area. This
stretch of the "river" does not lend itself to effective management of fish species, including the
Amargosa pupfish and the Amargosa speckled dace. Both of these species are being managed in
the Amargosa Canyon Natural Area/ACEC.
See also responses to 6-1 and 12-5.
Response to 13-2
The final Dumont Dunes Management Plan will provide procedures for signing the boundary of
the adjacent WSA (four signs per mile), trail crossings, and designated routes. The WSA will
continue to be monitored according to the Interim Wilderness Management Policy. One BLM
ranger currently provides law enforcement in the area, and the Dumont Dunes Management Plan
calls for an additional Visitor Services Ranger to work at Dumont and Rasor. Volunteers will be
organized into a dune patrol, distributing information on rules, regulations, and the proper use of
public lands. A brochure will be distributed providing information on the use and boundary of the
area, and the sensitivities of the WSA. If signing of the boundary and education is not effective
in preventing unauthorized activity in the WSA, the next management action will be fencing.
Response to 13-3
The rationale for expanding the OHV area is based on use which has occurred historically, as
well as the recognition of the unmanageability of an ambiguous boundary. Due to the shifting
sands, the boundary was unestablishable; thus, unintentional unauthorized activity has occurred
historically. Establishing a definite boundary will leave no room for misinterpretation and will
provide the tool for proper management. The outcome of this management decision is not the
spread of illegal activities, but the recognition of historical use and the establishment of a
manageable boundary.
See also response to 5a- 1.
Response to 13-4
See responses to 12-5 and 13-1.
Response to 13-5
The Bureau regrets that there was a typographical error in this section. We believe that adoption
of the amendment will, in fact, have a minor positive effect on the Yuma Clapper Rail (RaUus
longirostris yumanensis) through removing the possibility of impacts along that portion of Corridor
M which is proposed for deletion.
86
P.O. Box 307 (- ^ Qj,c<^ ^pt^
Boron, CA 93596 • /-'^
July 27, 1989
California Desert District, BUA ^m
ATTN: Plan Amendments I*!
1695 Spmce Street
Riverside, CA 92507
COMENTS ON THE PROPOSED 1988 AHiENDT-lENTS FOR THE COCA ?LAI^f
Amendment Two
14-1
But m proposing a new AC EC for Red Rock Canyon do you continue
to allow restricted OHV use in Nightmare Gulch? The tortoises don't
know when the raptors are nesting! The OHV route should be eliminated
To make this an ACEC and leave the routes open is an obvious submission
jto the pressure of the Gear Grinders.
Amendment Three
14-2
14-3
14-4
Again, the Gear Grinders will keep their trail through DeDeckera
Canyon. This trail is very similar to the Nightmare Gulch trail
and only serves the purpose of getting ^WDs from point A to point B.
Apy and all ACECs should be closed to vehicle use!
Amendment Five
I suspect that v/ith the proposed Fort Irwin Expansion you have little
choice but to delete the Camp Irwin Boundary expansion....
"Snendment Six
14-5 [^
14-6
But what are your plans for class designation once you delete the
Kramer Hills ACEC? Please advise if this will be made a Class L
larea to protect Category 2 tortoise populations.
endment Seven
^pw will you class the Dale Lake area once you have deleted the ACEC?
Amendment Nine
How can you justify wmdpowered gPi^rating facilities on Class L lands
The acres and acres of land surface disturbed in the installation and
service of wmdmachines is contradictory to Class L designation.
Furthermore steel trees are a big "0" in visual quality:
"Amendment Ten
9
14-7
But you propose to authorize 1900 cattle yearlong in the "Mojave National
^?M^^^^^®^"' ^^ cattle understand the constraints of limited use? Must
BLM make bighorn sheep compete with domestic animals for forage?. . .and
tortoises? To allow cattle grazing in the MNSA is a mockery of good
management. ^
Amendment Twelve
If Category 1 desert tortoise habitat was a primary reason for the
original Class L designation, then with the state and (emergency) federal
listing, shouldn't this be a separate issue?. . .separated from livestock
grazing and recreational activities?
Amendment Sixteen
I support the Chuckwalla Dune Thicket ACEC
Amendment Eighteen
There should be no grazing (not even day use) south of I-IO. If domestic
animals are infecting mountain sheep, then .v/hy do you. believe there
would be no transmittal of pathogen^ on a day-^use ^asis?j U^ppQ^I^I^^^ 3
Amendment Nineteen
Here again bighorn sheep will be impacted. I support Alternative C
Sincerel''
Hrff. Warren VI. Forgey
Response to Elizabeth Forgey
Response to 14-1
Vehicle use is already restricted in the proposed ACEC under a memorandum of understanding
(MOU) between the BLM and the California Department of Parks and Recreation. The area
is managed by State Parks as part of Red Rock Canyon State Park, except that BLM manages
mining and grazing. The Scenic Cliffs/Nightmare Gulch portion of the area is closed to vehicles
from February 1 to July 1 to protect sensitive resources. From July 1 to January 31, vehicle use
is allowed between the 16th day and the end of each month.
Response to 14-2
The Desert District has recommended that the 4-WD route between Eureka Valley and Saline
Valley should remain open. This decision was in response to a large number of requests from
the public during review of the CDCA Plan and during later route designation. The ultimate
decision will be made by Congress when it takes action on wilderness designation.
ACECs are not closed to vehicle access, although routes may be closed when necessary.
Response to 14-3
The reason for deletion of the Fort Irwin ACEC was that the portions of the ACEC within the
jurisdiction of the BLM contain no known cultural resources. There is no relationship to the
proposed expansion of Fort Irwin.
Response to 14-4
The Kramer Hills ACEC area will remain in the same multiple-use class as the surrounding area,
Class M, or moderate use. The entire area is within the Consolidation Zone of the Land Tenure
Adjustment Project (LTA). When the LTA Record of Decision is signed, Class M land within the
Consolidation Zone will become Class L.
Response to 14-5
The Dale Lake ACEC area will continue to be designated Class M, the same as the surrounding
lands.
Response to 14-6
The Multiple-Use Class Guidelines of the CDCA Plan specify that wind-generation power plants
may be allowed in Class L areas. The Class L designation also highlights the presence of sensitive
resources and insures that these areas will receive greater management attention. Proposed actions
are subject to environmental review according to the requirements of the National Environmental
Policy Act.
Response to Elizabeth Forgey (cont.)
Response to 14-7
Livestock grazing is compatible with limited use (Class L) in the East Mojave National Scenic
Area. Cattle numbers and their use of forage are monitored regularly. The majority of the scenic
area has been identified as being in "good" condition; the remaining areas are being managed to
improve their condition.
The CDCA Plan allocated forage to bighorn sheep before allocating any to cattle, in order to
reduce the chances of competition between the two. Competition for forage between bighorn
and cattle is usually not an issue in desert ranges, where water is often the limiting factor for
sheep. We are currently trying to ascertain whether or not there is competition of any kind
between cattle and tortoises. We will act to minimize these conflicts wherever possible. There
are many resources in the EMNSA; finding equitable solutions for balancing them is a goal of
the Bureau's multiple use mandate from Congress.
89
JOHN R. SWANSON . .
P. O. Box 6554 r" ~ ^ \
Minneapolis, Minn. 55406 I C ^^ ^ O l^ \ *! f%
'^^.^^ f->^<^k, \'\*t'i '^V»*\ f\T>v\*^ k^-r^vtiv\4 .
sr CO
rK* '^ §
"""■' CO '■'•1 ^'"'
flC' r> en •**•
««T. ,-0 "-^
5S'>
90
[Bs eA oiS[
<
BRISTLECOIME • CHAPTER
DEDICATED TO THE PRESERVATION
OF THE CALIFORNIA NATIVE FLORA
P.O. Box 330
Lone Pine CA, 935A5
July 26, 1989
In re: 1600
(C-060.23)
California Desert District, BLM
ATTN: Plan Amendments
1695 Spruce Street
Riverside CA, 92507 |0 •
Sf..
CD
-a-
CO
Gentlemen :
The folowing is in regard to your Environmental
I— Assessment of the Proposed 1988 Amendments to the Calif-
^j;;,iiia Desert Conservation Area Plan.
cirr
:.:3
We are most pleased to be able to say that we agreee
,v{:^th each of your preferred alternatives for the 19 pro-
...I
^.osed amendments.
Thank you for providing us with the opportunity
to comment upon the proposed amendments.
Yours very truly ,
Vincent Y^der, Conser vat y ion Chair
Bristlecone Chapter
California Native Plant Society
91
17-1
CALIFORNIA WiOOLi^OWERS ASSOCIATION
I 1 iAi
DATE
*^<3a Jul 3 1 :m O 28
July 27, 1989 -■>':-:.:,. /^
Gerald E. Hillier, District Manager
California Desert District
Bureau of Land Management |y
ATTN: Plan Amendments
1696 Spruce Street
Riverside, CA 92507
Dear Mr. Hillier:
The California Wool Growers Association appreciates the opportunity
to submit comments on the 1988 proposed amendments to the California
Desert Conservation Area Plan. The plan, and the continuing
amendment process, has been an ongoing and efficient mechanism to
manage the numerous resources of the desert for the groups who
utilize those vast renewable resources for recreation and their
livelihood. CWGA continues to support the Multiple use management of
public lands.
CWGA would like to comment on proposed amendments number 18 and 19.
The BLM decisions to accept amendment 18 and reject amendment 19 are
based in part on the interaction of domestic livestock and bighorn
sheep. It is therefore appropriate to address that issue first.
The bighorn fatality in the Warner Mountains is cited as one of the
principal reasons for acceptance of alternative A (amendment 18) and
acceptance of alternative C (Amendment 19). Dr. William J. Foreyt is
cited as the principle reference to that event. There have been
other works published on that event including a BLM Technical Review
Team's report which followed their meetings the following summer.
There are several important facts that were brought out in those TRT
meetings which are not brought forth in the literature cited in the
plan amendment.
First: It was unclear, at best, as to whether or not there had ever
l/been contact between domestic livestock and the bighorn sheep.
Don Torell Joe Esnoz Jay B Wilson
Pres.aeni Vice PresiOeni E.ecuiive Vice P'esideni
Ukian Caiitornia losi h.iis Canlomia Sacramenio Caulo'nia
Unifying the Voice of the California Sheep industry Since i860
1221 H Street, Suite 101 • Sacramento, California 95814-1910
(916) 444-8122
Q O
<^<^i^A oiT
Page 2 , Plan Ammendments
July 27, 1989
17-1
iSecond: The weather conditions that winter were severe. The snow was
abnormally deep combined with extremely cold temperatures over an
extended period of time. The snow depth limited the mobility of the
bighorn and covered much of the available forage. These factors
alone placed a great deal of stress on the animals.
17-2
Third: After the Fish and Game Department realized that a serious
problem existed in the Warner Mountain bighorn sheep population, they
decided to capture the surviving animals by helicopter and place them
on feed. The roundup and change from their familiar surroundings
placed additional stress to the surviving bighorn.
AMENDMENT 18
CWGA would like to oppose the acceptance of alternative A (Adopt
amendment) and support adoption of Alternative B (Reject Amendment).
AMENDMENT 19
CWGA supports adoption of alternative A. The potential permitee has
demonstrated a willingness to resolve any potential conflicts in the
development of an allotment management plan.
The plan identifies a potential impact of grazing on the Sand
Lananthus and the Monkey Flower. It is commonly accepted, and so
stated in the plan amendment, that these plants are not very
palatable to domestic sheep. Sheep, by nature, are very selective in
their grazing behavior, having the ability to selectively remove only
the part of any plant that they find desirable. If 200 lbs. of
forage are required per acre on this ephemeral allotment, and the
customary grazing restrictions are followed in the forthcoming
allotment management plan, there would be an abundance of palatable
feed available and subsequently, no reason for sheep to disturb the
aforementioned plants which they find undesirable. It can not be
expected that sheep would utilize this vegetation if more palatable
vegetation is available.
It is premature and erroneous to base this decision on the possible
conflict between bighorn sheep and domestic sheep or the presence of
a plant which domestic sheep find unpalatable.
Once again, we appreciate this opportunity to comment.
Sincerely, ,
Jay B. Wilson
Executive Vice President
93
Response to California Wool Growers Association
Response to 17-1
The California Department of Fish and Game maintains that both the Warner Mountains and
Lava Beds National Monument bighorn sheep die-offs were preceded by contact with domestic
sheep. The causative organism in both cases was found to be Pasturella sp. bacteria. Regardless
of the Warner Mountains case, potential impact to wild sheep from domestic sheep is also
documented by Sandoval (1988), in addition to the three references given in the environmental
assessment. In brief, the California Wool Growers Association provides no new information to
support rejection of Alternative A (adopt amendment).
Response to 17-2
The conflict between bighorn sheep and domestic sheep is documented and must be considered
as an impact. Potential impact to sensitive plant species from grazing or, secondarily, from
trampling cannot be ignored.
1/ CA Dept. Fish and Game, 1988. Summary regarding bighorn sheep, infectious diseases, and
livestock. State of California, the Resources Agency, Dept of Fish and Game (3pp.)
2/ Sandoval,A.V., 1988. Bighorn sheep die-off following association with domestic sheep: case
history. Desert Bighorn Council Transactions 32: 36-38.
94
'^SEA
O («
Kemcrest Chapter
National Audubon Society
P.O. Box 984
Ridgecrest, CA 93556
RECE^VEa
'383 JUL 3 \ ?H 3: 50
CHIP, il: S- -
■■"' • • - 11 — -. ■ 'l><
INIT. \
nm
18
IsOUTlNG
5 TO: DATE
California Desert District
Bureau of Land Management
1695 Spruce St.
Riverside CA 92507
Attn: 1988 Plan Amendments
Dear Mr. Hillier,
PIPE
sis
July 27, 1989
t"
Lutein
3p:
jVUN_j L—
At^i^^ ^
LACTIC
rm
18-1
This is an addition to our July 25 comments.
Concerning Amendment ^t6 Kramer Hills ACEC deletion - would it be possible to
adjust the ACEC boundaries to exclude a possible gold mine rather that deleting
the entire ACEC? We would like to work with you on a mutually agreeable
compromise if you delay action on this Amendment.
Thank you for your consideration.
Sincerely,
Donald W. Moore, President
95
Response to Kerncrest Chapter, National Audubon Society
Response to 18-1
Deletion of the Kramer Hills ACEC is not related to the mining operation in the area. The
subject gold mine is proposed for privately-owned land that is not under BLM jurisdiction. The
ACEC deletion is based on the finding that the area does not contain the significant cultural
resources for which it was originally designated.
96
f Rf . I^itedl^ates Department of the Interior
IN REPLY
REFER TO:
^^^^ JUL 3 I
'^ K)WER
j'lir T-:
iSlGT
UREAU OF RECLAMATION
COLORADO REGIONAL OFFICE
P.O. BOX 427
BOULDER CITY, NEVADA 89005
LC-159
ENV-6.000
Memorandum
To:
^^t. 2 7 1989
19
Mr. Gerald E. Hillier, District Manager, California
Desert District, Bureau of Land Management,
1695 Spruce Street, Riverside CA 92507
Attention: Plan Amendments
From: Regional Environmental Officer
Subject: Review of Environmental Assessment for the Proposed
1988 Plan Amendments to the California Desert
Conservation Area Plan of 1980 (Environmental
Assessment)
We have reviewed the subject plan as requested. The Bureau of
Reclamation presently has a ground water recharge test project in
the East Mesa area along a section of the abandoned Coachella
Canal. Water is released into the abandoned canal and allowed to
infiltrate into the underlying ground water aquifer.
We have been contemplating the use of spreading basins outside
the canal prism as part of our recharge project. Amendment Nine
m the plan recommends adopting the concept of changing Class "M"
lands to Class "L" lands. We would like to know what effect this
change in classification could have on our project.
We would appreciate a response to our memorandum at your earliest
convenience.
(jJjM,^^ £. /fx;
97
Response to U.S. Bureau of Reclamation, Lower Colorado Regional Office
Response to 19-1
BLM sent a memo to the Regional Environmental Officer indicating that the MUC change would
not affect the proposed recharge basins and that an environmental assessment would be required.
The memo described in detail the reasons for the change and noted the presence of several
ACECs and a Habitat Management Area. Also described were several of the sensitive wildlife
species found at the East Mesa. The memo concluded that "future environmental assessments for
recharge projects should consider all reasonable alternatives, including pumping rather than creating
spreading basins."
98
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99
\ktQA 6^1
STATE OF CALIFORNIA— THE RESOURCES AGENCY
GEORGE DEUKMEJIAN, Governor
DEPARTMENT OF PARKS AND RECREATION
Southern Region Headquarters
1333 Camino Del Rio South, Suite 200
San Diego, California 92108
(619) 237-7961
August 11, 1989
21
21-1
Ms. Irene Rice
California Desert District
Bureau of Land Management
1695 Spruce Street
Riverside, California 92507
Dear Ms. Rice:
Thank you for the opportunity to review the Environmental
Assessment prepared for your proposed 1988 Plan Amendments
to the California Desert Conservation Area Plan of 1980. The
California Department of Parks and Recreation supports the
designation of lands adjacent to Red Rock Canyon State Park
as an Area of Critical Environmental Concern (ACEC) . As noted
in your proposal, this amendment would provide additional, and
much needed, protection for wildlife, vegetation, rare and
endangered species of plants and animals, archeological
resources and paleontological sites on lands currently
co-managed by our two agencies. Our Department continues to
be interested in acquiring this land as an addition to Red Rock
Canyon State Park, and your proposal for increased protection
of these resources is consistent with our management goals for
the are*
Sinc^r^iy,
Kenneth
Southern
ones. Regional Director
eg ion
cc: R. Rayburn
G. McDaniel
J. Geary
]00
Response to CA Department of Parks and Recreation, San Diego
Response to 21-1
Your comment is noted.
101
;SfrUO
IS
P r ' I"
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Gear Grinden
Four Wked Drive Club
P.O. BOX 32
RIDOECRC8T. CAUF. SSBSB
Gerald E. Hillier, District Manager
California Desert District
Bureau of Land Management
1695 Spruce Street
Riverside, California 92507
RE: 1988 PROPOSED PLAN AMENDMENTS
22
Dear Mr. Hillier,
22r^
We, the members
submitt the foil
Desert Conservat
Amendments #2 -
Gear Grinders ha
Corridor and wit
reation. High De
agreements provi
of the Gear Grinders 4WD Club of Ridgecrest, would like to
owing comments to the 1988 Proposed Amendments to the California
ion Area Plan of 1980. We will specifically be addressing
Nightmare Gulch/Blackrock Canyon and #3 - Dedeckera Canyon. The
ve "Adopt-A-Trail" aggreements with the BLM for the Eureka/Saline
h both the BLM and the California Department of Parks and Rec-
sert Area (CDPR) for Nightmare Gulch/Blackrock Canyon. These
de for the maintenance of existing AWD trails.
First, however; if not for the announcement in the paper concerning these
proposed amendments, the Gear Grinders would not have known of these proposed
changes which could potentially affect our recreation in the two areas, as well
as the existing "Adopt-A-Trail" agreements. We feel it should be mandatory that
all parties to an Adopt-A-Trail agreement be notified of any potential manage-
ment changes to an an area covered by a cooperative management agreement.
CHAPTER 3, AFFECTED ENVIRONMENT
NIGHTMARE GULCH/BLACKROCK CANYON
We feel this proposal adds yet another layer of unecessary protection to this
area. Protection is already afforded the area by the 5 month closure to ALL
entry, during the raptors nesting season, as well as the 2 month vehicle closure
during the months of July thru January. Also, since the area is already managed
by both the CDPR and the BLM, an ACEC designation is unecessary and redundant.
The desert tortoise is protected in this area by the five month raptor closure,
as the tortoise is most active from March through June - when it returns to it's
burrows to hibernate through February (according to the BLM's Toroise literature).
The Statement is made that ". . . the Mojave ground squirrel may occur in por-
tions of the affected area." The actual presence of the Mojave ground squirrel in
the "affected area" has not been substaniated and so we assert that this is not a
valid reason for establishing an ACEC.
102
g^fe/l ozz
1988 Proposed Amendments, Page 3
Gear Grinders 4WD Club
Therefore, we strongly urge the BLM to REJECT Amentment 2, An ACEC for land ajacent
to Red Rock Canyon.
22-3
AMENDMENT THREE
NEW ACEC AT DEDECKERA CANYON
First, most people will ask, "Where is Dedeckera Canyon?" We, too, had to look
at the map to decide where it was located, and our immediate response was "Oh, the
Eureka/Saline Corridor." We hope this is just the name of the "canyon" and not
an attempt to change the historic name of the Eureka/Saline Corridor.
22-4
22-5
CHAPTER 2, ALTERNATIVES
We recommend that the current management be maintained, and the added title of
ACEC is not necessary.
On Page 2-2, under "Proponent's Reason for Submission", reasons stated for the
establishment of the new ACEC include: "There is evidence that they should be
protected from degradation", yet nowhere in the text is there any evidence given
substantiating the "degradation" to archaeological sites.
Also, "Camping in the canyon could be hazardous to both the natural resources
and to the campers, as flash floods may sweep down the canyon with great force."
First, camping in the canyon would be infrequent, at best, because of the camping
available at the Eureka Dunes and the hot springs in Saline Valley. The Gear
Grinders have camped twice at the north of the "narrows" while doing trail
maintenance, however, this is not the norm. The hazard of flash floods to
campers in the canyon is an emotional statement that is completely invalid. Any
canyon in the desert is a hazard in those conditions, and common sense should
protect most visitors. However, the statement does show that flash floods are
the source of more damage to natural resources than would be any campers. Indeed,
any evidence of campers would be removed.
CHAPTER 3, AFFECTED ENVIRONMENT
We agree that "the dolomite cliffs of the Last Chance Range provide nesting and
roosting habitat for raptors as well as habitat for bighorn sheep." This is not
justification, however, for an ACEC. (Page 3-3)
We agree "the cliffs of the Last Chance Range also provide habitat for many plant
species endemic to the Death Valley Region." However, neither is this a justi-
fication for an ACEC designation.
A cultural resource inventory "may" need to be done, but an ACEC designation solely
for the purpose of obtaining more funds is not appropriate. At the Desert Advisory
Council Meeting in Riverside this past June, a statement was made to the effect
that an ACEC designation could be used to obtain funding for a cultural resource
inventory. We do not feel that an ACEC designation is the appropriate vehicle for
obtaining funds to do a cultural resource inventory, and that is is not a valid
land management tatic.
103
£<6BAo^-z.
1988 Proposed Amendments, Page 2
Gear Grinders 4WD Club
22-2
As has already been noted, off road vehicle use in the area is restricted by an
MOU between the BLM and the State Park to certain portions of the year, which
minimizes the impact, if any, to wildlife and vegetation. The Nightmare Gulch
vehicle trail itself, being situated at the bottom of a steep-walled canyon,
does not permit vehicles to stray off the route and access to cultural artifacts,
such as the geoglyph on the rim of Nightmare Gulch. Access to the geoglyph is
greatly restricted by the same steep walls of the gulch, which makes hiking to the
geoglyph hazardous.
Mining is not a factor within the proposed ACEC. After checking the records of
the nine mining claims within the proposed ACEC, it was found that none are
active, as they have not filed plans of operation or notices of intent.
Under Recreation, the statement "There are four OHV routes of travel in this
area." is not accurate. The only two designated routes are the Nightmare Gulch
and Blackrock Canyon trails, which are NOT shown in their entirety (see attached
map #1), which together form a loop trip through the area (see attached map #2
for entire trail). Both are maintained as one trail by the Gear Grinders under
the Cooperative Management Agreement with the BLM and California Department of
Parks and Recreation, High Desert Area.
To address the Cultural portion, the geoglyph is up on the rim of Nightmare
Gulch, as stated previously, and is both both inaccessable by vehicle and
extremely difficult to find. Human intrusion will not be a factor on this
artifact, unless its location is posted.
CHAPTER 4, ENVIRONMENTAL CONSEQUENCES
In this section Pages 4-2 and 4-3, contains some statements that are either
disturbing or give no real indication as to the future status of the existing
OHV routes.
Under Wildlife, "An ACEC could allow greater restrictions on activities, such
as grazing and mineral exploration and development." Glenn Harris, the Ridgecrest
Resource Area Range Specialist, indicated to us, that although this area is part
of the Cantil Common Allotment, it is not suitable for grazing and is not used
for that purpose.
Again, under Recreation, there are only two designated routes. Other than the
seasonal closures, there are no valid reasons to close either Nightmare Gulch
or Blackrock Canyon to vehicle travel.
Under Cultural Resources and Paleontological Resources, the statement is made
that "Designation of this area as an ACEC would have little affect on cultural
or paleontological resources." Another statement is made that "Under the MOU
between BLM and Red Rock Canyon State Park, the area is currently managed as if
it were within the State Park." and also ". . . the area is already receiving
special management attention. . ." . Therefore, as vehicle usage within the
area is already well managed, and as neither grazing nor mining are currently
factors within the proposed ACEC, we do not feel that the establishment of an
ACEC is required or desirable.
104
^e <EA o
1988 Proposed Amendents, Page 4
Gear Grinders 4WD Club
22-6
22-7
22-8
CHAPTER A ENVIRONMENTAL CONSEQUENCES "
The area on either side of the Eureka/Saline Corridor is already a WSA and, as
such, is already protected from abuse. An ACEC designation would, therefore, be
redundant and, indeed, the statement is made under Cultural Resources that the
"level of protection for cultural resources now known to exist would not .
increase". In other words, adequate protection for the area already exists.
On Page 4-3, under Wildlife and Vegetation, the statement is made that "irrespon-
sible activities by users of the route could have detrimental effects. . .".
Nowhere is it stated that "irresponsible actibities" have occurred. In fact, in
another statement under Recreation (Page 3-4) it is noted that "Very little, if
any, trail proliferation has occurred." It appears from the statements within
this proposal that abuse of any kind resulting from the use of the Eureka/Saline
Corridor is "non-existent and therefore not a factor" in the this ACEC proposal.
Our basic concern in both the Nightmare Gulch/Blackrock Canyon and Eureka/Saline
Corridor areas, is the continued use of "existing trails". In the document -
"Areas of Critical Environmental Concern (ACEC's) - Policy and Procedures Guide-
lines , by the U.S. Department of the Interior, Bureau of Land Management - June
1980, that add to that concern. On Page 2, under 3, (a) it states ". . Provide
special management attention that will protect important environmental resources,
." and (b) "do this without unnecessarily or unreasonably restricting
users of these lands from uses that are compatible with that protection.". On
Page 3, under 7, - ". . ACEC identification "shall not, of itself, change or
prevent change of the management or use of public lands", however the statement
on Page 4, under 8, ". . . No activity incompatible or inconsistent with those
requirements shall be allowed or undertaken by BLM" makes us uneasy. History of
the Nightmare Gulch/Blackrock Canyon area shows a consistant attempt by either
the state or environmentalists to halt vehicle use in the area. If this area were
to designated an ACEC, in the "1989" Proposed Amendments would be an amendment
prohibiting vehicle travel through the the area, stating that it is an "incompat-
ible use" in an ACEC.
Therefore, we ask that the Bureau of Land Management reconsider it's original
recommendation, and reject the ACEC designation for BOTH the Nightmare Gulch/
Blackrock Canyon and the Dedeckera Canyon areas.
AMENDMENT 11 - DUMMONT DUNES OHV AREA
We would like to go on record as supporting your Preferred Alternative, to adopt
Alternative B, and add areas 2 and 3 to the OHV area, which would include the
historic use of the small dune areas, and would also improve the boundary manage-
ability. We also agree, that adding area 4 would serve no useful purpose.
Thank you for extending the deadline for comment till August 21, 1989. The late
date of receiving the document, and research required, would have made the original
date very difficult to have made. Thank you, also, for considering our comments.
Sincerely,
105
J^ /.J ^
Jeffery J. Tunnell
President
S^ GA D^7^
AAap^ I
/
AMENDMENT 2
PROPOSED ACEC BOUNDARY
New ACEC
Red Rock Canyon
\
106
"2^2 t^A ozz.
AVf\P ^2^
SCENIC CLIFFS /NTf^nHTMARE dJLCH FTBRUAP.Y 1 - .TIJL^ 1
ANIWAL SEASONAL CLOSURE APF^
This map shows the area that is closed to all public entrv fxxm February 1
to July 1 of each year. The area includes anproximately 1,200 acres of nublic
land in T.29S., R.37E., MDM, Sec. 23 SE*< (portion south and east of the
existing vehicle route). Sec. 2U S?=:, Sec. 25 tf-^ and Sl^, and Sec. 26 E^
(pxDTtion east of the existing vehicle route).
h 1/ L h i3 1
l^ipfwyy^/^rg^Tg-gg^
= Annual Seasonal Closur'e Bc-^undan/
= Desip,nated ORV Routes
107
SALTDALE NW QUADRANGLE
CALIFORNIA-KERN CO
7.5 MINUTE SERIES (TOPOGRAPHIC)
Response to Gear Grinders 4-WD Club
Response to 22-1
The BLM's preferred alternative for Amendment Two has changed from Alternative A to
Alternative B, No Action. The area is currently receiving several types of management attention,
including a Memorandum of Understanding (MOU) between the ELM and the California State
Department of Parks and Recreation, a Cooperative Management Agreement (CMA) between
State Parks, ELM, and the Audubon Society, and a CMA between State Parks, ELM, and the
Gear Grinders 4-WD Club. These are described in the decision page for this amendment. Adding
the ACEC designation would not improve the area's current management and protection.
Response to 22-2
The Environmental assessment was incorrect in stating that there are four designated OHV routes
of travel in the proposed ACEC. In fact, three designated routes pass through the area: EP-125
(Blackrock Canyon), EP-123 (Nightmare Gulch), and EP-120, which connects to EP-123. All three
of the routes are actually parts of one loop road. Routes EP-123 and EP-120 are closed from
February 1 to July 1; from July 1 to January 31, vehicle use is allowed only between the 16th day
and the end of each month.
Response to 22-3
The Canyon has been labeled on the map for this amendment; see the decision page.
The Bureau does not intend to change vehicle access on the Eureka/Saline Corridor or to change
the name of the corridor.
See also response to 14-2.
Response to 22-4
An example of a resource needing protection is the plant July gold (Dedeckera eurekensis) which
is found in Dedeckera Canyon. It is listed by the State of California as "Rare" and is also a
candidate for Federal listing. The goal of the ELM is to protect species so that listing will not
be necessary. This can better be accomplished by preventing degradation of habitat than by
attempting to mitigate damage after it has occurred. Dedeckara is one of the few woody plants
in this portion of the Eureka/Saline Corridor and could be inadvertently pulled out be campers
or picnickers for use in campfires. ACEC management could educate the public and forestall
such damage.
108
Response to Gear Grinders 4-WD Club (cont.)
Response to 22-5
Although each individual resource may, by itself, be insufficient justification for an ACEC
designation, the diverse mix of significant resources of the Eureka/Saline Corridor -- wildlife,
vegetation, cultural, scenic,and, and recreational values — require greater management attention
than is possible under the present Class "L" guidelines. An ACEC activity plan will address best
to manage the area for the multiple values found there. During the interim period until Congress
acts on wilderness designation, the Saline/Eureka Valley WSA is being managed according to Class
"L" guidelines.
Response to 22-6
During the interim period until Congress acts on wilderness designation, the Saline Valley WSA
is being managed according to Class "L" guidelines. See also response to 22-5.
Response to 22-7
See response to 22-5.
Response to 22-8
See responses to 14-2 and 22-1
109
m AUG 17 PM 2= 3 1
mr:'vv.. CA.
S'^e^A023
YUMA AUDUBON SOCIETY
P.O. BOX 6395
YUMA. ARIZONA 85366-6395
23
California Desert District
Eureai-.i. of Land Manaqement
ATTN! Plan Amendments
1695 Spruce Street
Riversidei California 92507
Dear Sir or Madam:
The followinq are Yuma, Audubon's comments on the Proposed 1988
Plan Amendments to the California Desert Conservation Area Plan of
19S0 Environmental Assessment,
In general 1 the 1988 amendments are a. considerable improvement
over earlier ones. There is much to support in this set of
amendments-! and most of them were generated by BLM. Several of the
amendments 3.ri= of special interest to us because they affect areas
relatively close to Yuma.
We support adoption of Amendments 1, 2i and 3. These areas are all
worthy of ACEC designation because of the outstanding animalsi
plantsi and cultural resources they contain.
We are familiar with the Coyote Mountains area proposed for an
expanded ACEC in Amendment 4 and support its adoption. This is an
area of impressive biological and geological interest, supporting
the Magic Gecko, which until recently wasn't even known to exist
in the United States. There are very few ACECs established for
pa laeontolog i cal resources, and we warmly welcome protection of
such resources through expansion of this ACEC.
We also support Amendments 8 and 9. We only wish stronger measures
had been adopted earlier to protect such incredible areas as the
Yuha Desert and the East Mesa. The cultural resources of these
areas are a national treasure and should not be squandered on ORV
play. The Flat-tailed Horned Lizard is finally getting some of the
attention it deserves and hopefully Amendment 8 will help to
arrest its decline. BLM, the Fish & Wildlife Service, the
military, and Cal Fish ■!< Game all need to devote constant
attention to this jeopardized species.
ELM should assess cumulative effects on the Federal Endangered
Yuma Clapper Pail and California Threatened and Federal Candidate
Black Rail. This means assessing the potential effects of lining
the All-American Canal, as the Bureau of Reclamation is proposing.
110
23-1
For similar reasons diii 1 dl i f e, ORVsi and land disposal potential)
me support Amendrrient 10 tijhich covers part of the East Mohave.
He strongly urge BLM to reject Amendment 11. All you are doing by
expanding the open area is encouraging ORV users to invade
protected areas in ever -ui den ing circles. As soon as you open a
neiu e.ri^a to them^ they 'xiill expand into the adjacent non-open
ar(^a. This especially concerns us because an open area ijould
adjoin tu.!0 more WSAs (220 and 222- if your proposed action is
adopted. Right nouji the limited access areas serve ior should
serve with adequate enforcement) as a buffer between the exisi-ing
open ORV area, and the WSAs.
We agree with BLM that Amendment 12 should be rejected. We are
especially concerned li-'ith impacts on the adjacent Desert Tortoise,
especially since the Desert Tortoise has become an endangered
species and in light of the need to manage so as to recover the
species from endangered status.
We strongly support Amendments 13i 14, and 15. We are especially
familiar with the Corridor M area and believe that the importance
of the cultural and biological resources (including a Federal
endangered species and a state-listed threatened species) Justify
not alloiJlng power line construction in this area.
Amendment 16 should be adopted, as BLM recommends. The Chuckwalla
area is a unique collection of plants and animals, not only in
California, but in the world. The presence of lush desert riparian
vegetation and dunes make this an area to treasure.
We are glad to see that BLM recommends closing the Palen Dry La^ e
ACEC to vehicle access because of the early human cultural
resources (Amendment 17). There is still much to be learned of the
early inhabitants of California, and finds are more often than not
fortuitous. Significant areas must be preserved from the
destruction of ORVs and livestoc^' trampling if we are to learn
more about the first inhabitants of the California desert.
We support BLM's recommendations on Amendments 18 ^ adopt) and 19
(reject). Domestic sheep present too great a hazard to Desert
Bighorn to allow them in the same area. These amendments involve
only ephemeral allotments. We feel it is much better to allow the
native wildlife to utilize whatever plants the livestock would
otherwise be using and the ecology of this area is presumably tied
to fluctuations in rainfall. Remo-'ing the vegetation through
invasion by exotic animals in wet years reduces the native
wildlife to a more steady or even disadvantaged state in terms of
availability of vegetation. We believe this is a dangerous course
to follow in such a delicate ecosystem where water (including that
stored in vegetation) means life.
In general, then, we can say that we support BLM's recommendations
for the 1938 amendments. However, we are very much concerned about
Amendment 11 and feel that it should not be adopted in any form,
111
be it Alternative A, B, or C. Amendment 11 is our main point of
disagreement with ELM.
Thank you for the opportunity to comment on this proposed action,
Sincerelyi
^^ X ^^^^5:zS:.
Gary W. Meister
Presi dent
3
112
Response to Yuma Audubon Society
Response to 23-1
See responses to 5a- 1, 13-2, and 24-2.
113
S^SA O^^
oi,c>~
I.-5 tr -
«4K.8 PjijQ.
ELDEN HUGHES
14045 Honeysuckle Lane
Whittier, California 90604
(213) 941-5306
mm
August 16, 1989
24
24-1
24-2
24-3
California Desert District
Bureau of Land Management
Attn: Plan Amendments
1695 Spruce Street
Riverside, CA 92507
RE: Amendment 11, Change class M to class I and vehicle access
from Limited to open in area adjacent to dumont dunes OHV Area.
None of the alternatives which enlarge the OHV area are adequate.
Essentially they reward the past "breaking of the rules/ lack of
enforcement" by saying if the area has been trashed, let's
include it in the OHV area.
The buffer is neededo protect the WSA's, the ACEC, and the
Amargosa. To say "the present boundary is unmanageable because
the area of the dunes, themselves, changes constantly due to the
shifting of the sands" is to display ignorance of both the dunes
and management.
To make the statements (4-13) that there is a high probability of
cultural sites, but we will avoid the significant ones, while at
the same time saying this is the area of historic use, makes the
BLM look less than competent.
I recommend alternative D. Likely the camping areas need to be
provided for, but neither A B or C provide adequate protection
for surrounding resources.
Sincerely,
114
Response to Eldon Hughes
Response to 24-1
See response to 5a- 1 and 13-3.
Response to 24-2
The writer's concern about needing a buffer to protect the WSAs, the ACEC, and the Amargosa
River was relieved by an on-site visit with BLM personnel to observe the area and review
management actions which are planned for protection of the areas of concern.
Response to 24-3
The term "historic use" refers to historic recreational use.
See also response to 12-4.
115
j'ffft^A czS^
Mary L. Grimsley R F.
1 — Pi(^r i 'i 'v
August 10, 1989
M AUG i 8 FH 3: G2
Gerald E. Hillier, District Manager
California Desert District
Bureau of Land Management
1695 Spruce Street
Riverside, Ca. 92507
RE: 1988 Proposed Plan Amendments
ro;
DATE
INIT.
5^_
ADM
PA
Ad.m'n
_BJHS_„
Mk'xl
AiVls
ACTION DY:
PETURN TO:
1012 N. Sierra View
Ridgecrest, CA 93555
619-446-3458
--i
25
Dear Jerry,
I would like to thank you for extending the public comment period to August 21.
Enclosed are my personal comments on a couple of the amendments with which I am
familiar with.
As you may know, I am a member of the Gear Grinders 4WD Club in Ridgecrest, and the
Gear Grinders has both of the "adopt-a-trail" agreements for the Nightmare Gulch/
Blackrock Canyon area (amendment 2) and the Eureka/Saline Corridor (amendment 3 -
Dedeckera Canyon). We have had both of the agreements for several years, and have
done the required maintenace of each trail each year, so I have on the ground
knowledge of both areas.
AMENDMENT 2 - NIGHTMARE GULCH/BLACKROCK CANYON
I have been involved with helping to retain the "use of vehicles on existing trails"
in this area since the time the State applied to have the area added to Red Rock
State Park. At that^time, the State demonstrated that existing uses were incompat-
able with State guiolines, and said, in-as-much, that Nightmare Gulch would be
closed to vehicle travel. Therefore, the BLM retained the area but has allowed the
State to manage it with the provision that vehicle travel would be permitted in the
area. Next came the attempt, by environmentalists, to get the area closed to vehicle
travel, which ended in the ^-month time sharing that exists today. Then came the
raptor closure from Feb. 1 - July 1 by the Audubon Society. Now the Audobon Society
has proposed an ACEC designation for the area. How nice. Next year they will have
an amendment that vehicle travel is incompatible with an ACEC designation, that is of
course if a vehicle closure is not installed during the ACEC planning process. Jerry,
this was all decided already, with a trip by the BLM Desert Advisory Council and BLM
personel through Nightmare Gulch, seeing that the slow vehicle travel through the
Gulch was not having a negative impact on either vegetation or wildlife. Mother
nature has changed the Gulch so significantly over the last ten years, it is sometiriies
hard to believe it is the same canyon bottom. I have seen it scrubbed out down to the
bedrock, and the next year it is covered. I have seen the sides cave in, creating a
lake behind the cave-in and raising the canyon bottom ten feet. The next year water
had carved it's way through the cave-in, and the bottom was lowered.
116
Mary L Grimsley
Comments re; Proposed
Amendments, Page 2
25-1
I feel this is another layer of unecessary protection being added to this area.
The protection that is already in place for the area with the 5-month closure
to all entry during raptor breeding/nesting, along with the State Department of
Parks and Recreation (SDPR) management, with the BLM overseeing, an ACEC desig-
nation is unecessary.
Reading information phamphlets provided by the BLM, I found that the most active
time for the desert Tortoise is March through June, when they pretty much return to
their burrows, to hibernate till February. This is during the raptor breeding/
nesting time, when the canyon is already closed, so this is not a valid reason for
the proposed ACEC.
25-2
In reference to: "The Mojave ground squirrel may occur in portions of the affected
area.", is an inappropriate and invalid statement. Dinosaurs "may occur", but no
one has seen them. Page 3-2.
By the BLM's own admission, "A memorandum of Understanding (MOU) with Red Rock
State Park currently affords protection for wildlife by controlling OHV use."
Page 3-2. With 5 months of the year closed to OHV (and all other uses), and the
other seven months are affected by the 1st half of the month closed to OHV use,
the OHV use is very minimal.
On page 3-3, under vegetation, "The MOU with Red Rock State Park affords the plants
some protection by controlling OHV use", and the statements, ". . . judged by
California Native Plant Society to be vulnerable under present circumstances." and
". . . the CNPS considers vulnerable under present circumstances" are all
irrelevant and misleading. Considering the forces of Mother Nature, which have
changed the bottom of Nightmare Gulch from scrubbing it out down to the bedrock,
and then, filling it back up with sand and rock, and still the plants come back
and grow and survive. Unless, of course, the CNPS isn't talking about Nightmare
Gulch, but the surrounding areas, of which there are no OHV trails or tracks.
As with mining affecting the wildlife and plants, after checking the records, there
are 9 mining claims within the proposed ACEC, none of which are active, for they
have not filed plans of operation or notices of intent.
Under recreation, page 3-3, the statement "There are four OHV routes of travel in
this area." is completely untrue and misleading. The only two designated routes
are the Nightmare Gulch trail and the Blackrock Canyon trail - which together form
a loop trip through the area. The other two trails (marked on Appendices Map-attached)
have not been designated trails for quite some time. On the map in the Proposed
1988 Plan amendments, in the Appendices, the complete trail system of Nightmare Gulch
and Blackrock Canyons are not shown, so I have attached a second map (map #2) which
was printed out of the file which can be found at the Ridgecrest BLM Office.
I also take to task the statement ". . . frequent day use of the area for hiking
by people enjoying the area's scenic qualities and interesting native flora and
fauna." Hikers do not have a monopoly on enjoying scenic qualities and fora and
fauna. That is the same reason we, 4-wheelers, enjoying driving the gulch, to show
new people and visitors the unique geologic formations, as well as "seeing" various
raptors, bobcat, and fox. The wildlife are not as afraid of vehicles as the public
is being led to believe. Man poses more of a threat on foot than in a vehicle.
The geoglyph is up on the rim of Nightmare Gulch, and is extremely hard to find, even
when you know what to look for. Being basically unkown, has protected it so far. Do
not sign it to bring it more attention, or it will disappear. Weather is it's
greatest enemy.
117
Mary L. Grimsley
Comments re; Proposed *88 Amendments, Page 3
25-3
In Chapter 4, Environmental Consequences, on Page 4-2 & 4-3, there are some state-
ments that are confusing and give no real indication asn:he future of these existing
OHV routes.
Under Wildlife, "An ACEC could allow greater restrictions on activities, such as
grazing and mineral exploration and development". I went to the Ridgecrest BLM
Office to investigate grazing and mining in the area. According to Glenn Harris,
Ridgecrest Resource Area Range Specialist, this area is part of the Cantil Common
Allot'^ent, however it is not used for grazing. It was part of the old "stock
driveway". According to Mr. Harris, "this area doesn't lend itself to grazing".
I checked the Red Rock/Nightmare Gulch file in the Ridgecrest office, and also
talked to the ranger in charge of mining claims, and there are nine (9) claims,
of which none are active as nq/Gne has filed a Plan of Operation or an Intent to
Mine.
25-4
Again, under Recreation, there are only TWO designated routes. Other than the
seasonal closures, there are no valid reasons to close either Nightmare Gulch or
Blackrock Canyon.
Under Cultural Resources and Paleontological Resources, the state*^is made that
"Designation of this area as an ACEC would have little affect on cultural or
paleontological resources." 'Ilien why make the area an ACEC? Another statement,
"Under the MOU between BLM and the Red Rock Canyon State Park, the area is currently
managed as if it were within the State Park.", and (in summary) ". . . the area
is already receiving special managQHipnt attention . . .". Then why make the
area an ACEC? Additional restrictions on grazing no longer applies, and with the
strict mining regulations, the fact that mining is generally around the peremitter
of the proposed ACEC, and that no raining is currently being proposed by the current
mine/claim holders, I do not f«el that an ACEC is necessary, but redundant.
Therefore, I strongly urge. the Bureau of Land Management to reject Amendment 2, an
ACEC for Land Adacent to Red Rock Canyon.
AMENDMENT 3 - NEW ACEC AT DEDECKERA CANYON
On Page 2-2, under Proponent's Reason for Submission, reason's stated for the
establishment of the new ACEC include, ". . there is evidence that they [archaeo-
logical sites] should be protected from degradation", yet, nowhere in the text is
there any evidence given substantiating the "degradation" to any sites.
Also, "Camping in the canyon could be hazardous to both the natural resources and to
the campers, as flash floods may sweep down the canyon with great force." First,
camping in the canyon is infrequent at best, considering the camping available at
Eureka Dunes and at the hot springs in Saline Valley. The Gear Grinders have camped
twice north of, near, the "narrows", while doing trail maintenance, however, this is
not the norm. The hazard of "flash floods to campers in the canyon" is an emotional
statement that is completely invalid. Any canyon in the desert is a hazard in those
conditions. Both Ridgecrest and Olancha should be moved from their present locations
to high ground. However, the statement does prove one point: flash floods cause
more damage to the natural resources as it "sweeps down the canyon with great force",
than would any campers. In fact, any evidence of campers would be removed.
118
25-5
25-6
Mary L. Grimsley
Comments re: Proposed '88 Amendments, Page 4
I am sure that "the dolomite cliffs of the Last Chance Range [probably] provide
nesting and roosting habitat for raptors as well as habitat for bighorn sheep."
However, this does not mean an ACEC is necessary.
I agree "the cliffs of the Last Chance Range also provide habitat for many plant
species endemic to the Death Valley Region"(Page 3-3). 1 recently learned that
Ms. Mary Dedecker visited Cerro Gordo, and pointed out a Category 2 canidate for
listing plant - July gold (Dedeckera eurekensis) around the mining camp, which I
would assume is growing all through the Inyo Mountains, and not just in Dedeckera
Canyon. I feel the above statement could be applied throughout the region, and
is a weak argument for an ACEC designation.
A cultural resource inventory "may" need to be done, but an ACEC designation solely
for the purpose of obtaining more funds to do so, [according to a source which
attended the recent Desert Advisory Council meeting in Riverside], is not appropri-
ate.
Stated under Recreation, "Very little, if any trail proliferation has occurred."
The terrain on each side of the corridor does not lend itself to cross-country
travel, hence, there is no trail proliferation. Also stated, "Some visitors to
the area hike up side canyons to examine the proposed ACEC's unique flora and
fauna". This statement eludes to the fact where the unique flora and fauna is
located, ana not where vehicles are likely to disturb them. Page 3-4.
In Chapter 4, Environmental Consequences, the statement under Wildlife and Vegetation
"An ACEC could give added protection to the sensitive plant species July gold by
controlling the activities of users of the Eureka-Saline Corridor". What kind of
"controlls" are you talking about, when under Recreation, the statement is made,
"Since the only route within the proposed ACEC would remain open, there should be
no effect on any recreation activities . . ." ?? One statement contradicts
the other.
Under Alternative B, "Any proliferation of the Eureka-Saline Corridor or irresponsible
activities by users of the route could have detrimental effects . . . " is an
unsubstantiated and invalid statement.
Therefore, I strongly urge the Bureau of Land Management to reject Amendment 3, a
New ACEC at Dedecera Canyon.
AMENDMENT 11,
DUMMONT DUNES
I do support the BLM position on adopting Alternative B for the Dummont Dunes, as
it would - as stated on Page 2-5 "include the majority of the historic OHV use area,
provide for family and individual OHV activity, and would improve the boundary
manageability." I also agree that adding Area 4 is not necessary.
Thank you for considering my thoughts and comments on these proposed amendments. I
hope they will help you make that difficult decision.
119
Sincerely,
Mary L. Grimsley
Response to Mary Grimsley
Response to 25-1
See response to 22-1
Response to 25-2
See response to 22-2
Response to 25-3
See response to 22-2
Response to 25-4
See response to 22-1.
Response to 25-5
See response to 22-5.
Response to 25-6
See response to 22-4.
120
SSea o 2^
^'/Of ;
19 August 1989
;oi.j AUG 2\ ^H !• 23
California Desert District Office _
Bureau of Land Management. ^ - _'•;>••'•"»
ATTN: Plan Amendments '"^
1695 Spruce Street 26
Riverside California
Dear Mr. Hillier,
26-1
The purpose of my letter is to provide clarification of the back country vehicle
use opportunities in the proposed Red Rock Canyon ACEC(Amendment #2). The plan
indicates that there four designated routes of travel in the ACEC area. The map
provided does not correctly show the trails available for use. Enclosure (1) presents a
corrected map showing both open and existing closed trails.
EP 123,EP 120 and EP 125 form part of a loop trail which is maintained under
an Adopt-A-Trail agreement between the GearGrinders 4WD Club and the BLM.
Vehicle use of EP 123 and EP 120 is prohibited from the 1st through the 15th of each
month. Further, EP 123 and EP 120 are closed to all public entry from February
through June to protect raptor nesting. Trails 1 through 5, shown on the attached map,
are closed to vehicle use. Has the State Park been illegally denying vehicle access?
Clarification of which trails are suppose to be open to back country vehicle use is
needed.
Nightmare Gulch(EP 123) and Blackrock Canyon(EP 125) are unique areas
and deserve special protection. In my view, this area is currently receiving that
protection. Unfortunately, I view the proposed ACEC status as simply another strategy
for the ultra-environmentalists to "get the vehicles out". A goal that they have been
working toward for 10 years.
I just finished reviewing the Afton Canyon ACEC Management Plan, and was
very disillusioned to see vehicle routes in non-sensitive areas arbitrarily closed. With
these fears in mind, I must oppose ACEC status for Red Rock Canyon and recommend
rejection of Amendment #2.
' -lerry D. Grimsley -^
lOlii N. oierra View
Ridgecrest Ca. 93555
121
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122
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Response to Jerry D. Grimsley
Response to 26-1
See response to 22-2.
123
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,. ELDEN HUGHES
14045 Honeysuckle Lane
n J Whittier, California 90604
i^ijiRlCr
(213) 941-5306
August 16, 1989
27-1
27
California Desert District
Bureau of Land Management
Attn: Plan Amendments
1695 Spruce Street
Riverside, CA 92507
RE: Amendments Deferred: 88-p-15 Remove all grazing in the East
Mojave National Scenic Area west of Kelbaker Road.
I submitted the above amendment in behalf of the Sierra Club.
The amendment discussed scenic values in the Kelso dunes which
were note addressed in reason for deferment. The stated reason
for deferment is an evaluation in an upcoming study.
The bighorn are at risk. The scholarly papers submitted with the
amendment, document the risk. If the BLM is funding the upcoming
evaluation, then it should state who is doing the study, when
it will be completed, what criteria will be used to determine the
"at risk" status of the bighorn sheep, and who will submit the
appropriate amendment.
The deferral statement is totally inadequate.
Sincerely,
Response to Eldon Hughes
Response to 27-1
Conflicts between cattle and scenic values in a small area can be resolved without eliminating
grazing on 375,000 acres. The Kelso Dunes are largely untouched by cattle or humans. Efforts
are currently underway to reduce the number of cattle in the parts of the dunes that receive the
most visitor use.
There are presently two separate studies on possible conflicts between bighorn sheep and cattle.
Although cattle have been blamed for spreading diseases to bighorn, there is no clear evidence
that they carry the diseases in question. In the first study, the Department of Fish and Game will
study pathogens in the blood serum of bighorn and cattle in the Granite Mountains. In the second
study, Dr. John Weyhausen has compared bighorn sheep in the Marble Mountains (no grazing)
with sheep in the Old Woman Mountains (grazed). He is now comparing bighorn in the Old Dad
Mountains (no grazing) with bighorn in the Granite Mountains (grazed). If the results of the
above studies show that cattle grazing is depressing the local bighorn populations, BLM will attempt
to correct the situation. A Plan Amendment will be introduced, if necessary. Proposals from other
private or governmental agencies will also be considered at that time. If the results of the studies
fail to establish a link between cattle and sheep populations, BLM will continue to support and
facilitate studies that might identify factors that limit the bighorn sheep population.
125
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.„-„,„ SIERRA CLUB
" "iSotiAE^m California Regional Conservation Committee
August 16, 1989
28
28-1
28-2
California Desert District
Bureau of Land Management
Attn: Plan Amendments
1695 Spruce Street
Riverside, CA 92507
Dear Mr. HilXier^
The Sierra Club offers the following comments on the 1988
Proposed Plan Amendments.
First, once again, we repeat that one of the plan amendments
ought to be to eliminate the cycle of annual plan amendments.
The annual self examination hardly gives any Resource Area
Manager the discretion to make a decision based on the existing
plan before one of the proposed decisions gets tossed up as a
Plan Amendment. The annual process is extremely labor intensive
costly and time consuming. It defeats the purpose of planning '
which is to GIVE DIRECTION AND GUIDANCE FOR INDIVIDUAL DECISIONS
BY RESOURCE AREA MANAGERS. The inefficiency of the annual
process is illustrated by the fact that it is halfway into 1989
and we are :ust now looking at proposed 1988 amendments. Before
these were available to the public the deadline had passed for
submitting the 1989 proposed amendments.
Comments on specific Plan Amendments
1. Sierra Club supports the designation of the new ACEC at Rodman
Mountains .
2. Sierra Club supports the new ACEC adjacent to Red Rock Canyon
in so far as it improves possible management of the area until
the lands are deeded to Red Rock Canyon State Park as is proposed
m S.ll, H.R. 780.
We find the justification very curious.
BLM resisted transferring these lands to Red Rock Canyon
State Park It agreed to do when the park was established. Much
toot dragging by BLM occurred because BLM has maintained that it
felt It necessary to retain title to the lands so that:
mining could continue;
grazing could contiue:
and ORV could continue.
However ,
A. ORV traffic has had to be curtailed because it was
disturbing eagle nests and traversed the very canyons where the
126
28-2
28-3
A endangered plants were trying to survive.
p B. if it is designated as an ACEC, BLM "could allow greater
restrictions on activities such as ... mineral explorationn and
development. "
C. if it is designated an ACEC, BLM could place "greater
restrictions on activities such as grazing...."
What justification then remains for continued BLM title?
Are the few blades of grass in this portion of one desert
allotment more important than the endangered plant species?
We also noticed that grazing restrictions will help the
wildlife but not the plants. Except for preparing the necessary
ACEC plan, (probably with funds from the State Fish and Game
Commission) BLM will have little on the ground responsibility in
this area, since it is being patrolled already by State Park
rangers. As it states in the EA portion, the area is already
being managed as part of the State Park. Why then the
resistance to giving the State Park title?
Since, the "No Action" alternative admits that the current
Desert Plan is not capable of maintaining the habitat for the
Mojave Ground Squirrel, Desert Tortoise, as there is little
choice but to opt for the ACEC at present.
There is an omission in the environmental assessment in that
it does not spell out what the relationship will be between this
ACEC and the ACEC just to the east that encompasses Last Chance
Canyon where there are at least 60 sites of historic and
prehistoric interest.
28-4
3. We support the designation of the ACEC for Dedeckera Canyon.
We are however, confused about the intent and probable
management actions contemplated for this ACEC - they seem
inconsistent and at cross purposes. The mere designation will
not protect anything unless the land managers have something to
implement. There is an assertion that there will be additional
protection by "controlling the actions of users on the Saline-
Eureka Corridor." However, it also states that there will be no
effect on recreation activities which are in conformance with the
IMP. (Does that mean that BLM is aware of activities not in
conformance and cannot control those activities without the
designation of the ACEC? What does that say about non-
conformance in areas in which there is no ACEC?) It also states
that the open route could be a potential threat to adjacent
resources (presumably the Dedeckera for which the canyon is
named), and that the route will remain open.
Does the designation of this ACEC indicate that protection
of the recently discovered and sensitive Dedeckera is considered
more important? How important is it? Obviously not as important
as keeping the route open. How will the actions of users of the
route be controlled without having an effect on the recreation
activities of users of the canyon?
4. We support the expansion of the Coyote Mountains ACEC.
2
127
28-5
28-6
28-7
What does "increased management priority mean" in terms of
management direction? The document should be able to say
plainly that collection of fossils will not be allowed in the
ACEC if that is the intent. That does seem to be the management
direction when one reads the section on effects of the
designation on Recreation. Is there a management plan for the
existing ACEC? Would this additional area operate under the same
general management plan? Was this information discovered during
the preparation of that ACEC?
5. BLM is not entitled to simply abandon the ACEC site if it is
important. What will Fort Irwin be doing to protect the cultural
resource? Appendix D, Page 74 of the Desert Plan states that the
Secretary of Defense has relingquished responsibility for
cultural preservation to the Secretary of Interior, thus it
appears that acceptance of the Plan Amendment would not be in
cgnformit with existing policy.
TTand 7. Are we to presume that the Kramer Hills and Dale Lake
sites have been decimated? If there is nothing there, it makes
sense to remove the designation. If there was a mapping error,
then the correct sites should be located. Current archaeologisti^
on staff at BLM are surely no more or less susceptible to mappinq
errors than the members of the Desert Plan staff who located the
site originally. Where is the assessment of the effect of
removing this ACEC designation to the Desert Tortoise? FLrar.er
Hills lies within important tortoise habitat.
28-8
3. Sierra Club would support a change from Class M to Class C if
that is what Is required to protect the Flat Tailed Horned
T.izard, geoglyphs and other cultural resorces. It appears that
changing to Class L would only prevent NEW sources of impact,
,3uch as land disposal. Existing plans have NOT, according to
5LH'*s own statements, succeeded in halting the degradation. The
principal culprit is ORV use, but the class change would not do
anything more to restrict vehicle activity. If in the absence of
wiineral entry problems and land disposal BLH is unable to save
the resource, what good will the class change do? It appears to
be too little, and too late.
9. Sierra Club supports the class change for East Mesa.
The map and the text are not consistent. The text states
28-9 fciiat the area of high ORV use around Gordon's Well will be
excluded, but the map appears to include the area. Which is it
oaing to be?
There is another inconsistency with respect to the Desert
ilan. Under the Motorized Vehicle Element, the current ACEC is
indicated as only being available for approved routes of travel,
23- "lo^^^^-^ ^^ ther*rf is ORV play and associated camping as is described,
it is not supposed to be perraitted. Such use should be
described.
There is an inadequate description of the existing ORV use.
128
28-10
2&-11
A There is an inadequate description of the existing ORV use.
Low to moderate use, when it comes to ORV areas, means that
there may still be 6 or 8 foot creosote bushes standing.
Something more quantitative is needed. The Sierra Club has
personally viewed several groups of 10 or more ORV support
vehicles (camper, truck, motorhome, etc.) at many points along
the west side of the Coachella Canal on the same day. There is
practically a "highway" which runs alongside the canal.
As in the case with Amendment 8, the principal culprit in
endangering the resources appears to be ORV use. If such use is
not going to be constrained then restrictions on possible dangers
from landfills, mines or agriculture will not be enough to save
the resource.
2&-12
10. The Sierra Club has cosistently supported more protective
class designations inside the national scenic area. Progress is
being made — it moved from unclassifed to M, now we're moving
from M to L.
11. and 12. Sierra Club opposes both class changes. The first,
for the expansion of the Dumont Dunes Open area, is uncalled for,
and would be extremely destructive of the Wilderness Study Area
resource values. Never have we seen an ORV area in which users
stayed where they were supposed to unless there is an enormous
natural barrier. Making the ORV boundary contiguous with the WSA
boundary (fortunately not proposed for overlap as in the case of
the Imperial Dunes) is inviting conflict along the boundary.
Also, the natural resources of Amargosa Canyon would be
endangered. We would prefer the area have no change than one
which rewards unauthorized and illegal use outside the open area
by expanding the open area boundaries.
16. Sierra Club supports the change in Chuckwalla Dune Thicket
Motor Vehicle Access.
Please correct the document. One place refers to a
September 1981 ACEC plan implementation, another to a 1982 ACEC
plan.
17., 18., 19. We support the changes proposed in Amendments 17
and 18, and oppose the grazing increase of Ameendment 19
Sincerely,
Jira.ith X. Anderson
for the Desert Committee
JA:ts
4
129
Response to Sierra Club, Judith Anderson
Response to 28-1
Your comment is noted.
Response to 28-2
Your comment is noted.
Response to 28-3
The Last Chance ACEC is approximately 4 miles north of the proposed ACEC. It is designated
for protection of cultural resources and has no particular relationship to the proposed ACEC.
Response to 28-4
See responses to 14-2, 22-4, and 22-5.
Response to 28-5
The term "increased management priority" means that fossil resources within the Coyote Mountain
area would receive greater attention. Prohibition of fossil collection became necessary when
Bureau personnel noted an alarming reduction in fossil numbers in prime areas. Fossil collection
in the expansion area was placed under a temporary prohibition ordering April, 1988; this restriction
will become permanent with the approval of this amendment. The expansion area will be managed
under the prescription of the ACEC activity plan completed in 1987.
Response to 28-6
The National Historic Preservation Act (Sections 106 and 110) requires the Army to manage
cultural resources within the boundaries of lands under the Department of the Army's jurisdiction.
In addition, the Army has a memorandum of Agreement with the State Historic Preservation
Officer and the Advisory Council on Historic Preservation to assist Fort Irwin personnel in their
identification and inventory program on cultural resources.
See also response to 11-1.
Response to 28-7
The Dale Lake and Kramer Hills ACECs were established by the CDCA Plan in 1980. The field
data used by the CDCA staff was based on resource information and recommendations submitted
by individuals from the private sector. Neither of the proposed areas was evaluated
130
Response to Sierra Club, Judith Anderson (cont.)
in the field by BLM archaeologists prior to their designation as cultural ACECs. Attempts by
BLM archaeologists (since 1980) to locate significant archaeological sites within the boundaries
of both the Dale Lake and Kramer Hills ACECs have been unsuccessful. Five sparse lithic scatters
comprise the total number of recorded sites within the Dale Lake ACEC. One site was surface
collected by San Bernardino County Museum and has lost its integrity. Scientific values of
remaining sites are marginal. No cultural resources are recorded within the boundaries of the
Kramer Hills ACEC.
Response to 28-8
The condition of resources within the Yuha Desert Management Plan area has stabilized through
a series of actions initiated by the 1985 Yuha Desert Management Plan. We acknowledged in
that plan that existing measures enacted since 1980 had been insufficient to prevent a deterioration
of resources. Some of the actions instituted to reverse the downward trend include increased
patrol, better signing, closing of some routes, limiting competitive racing, and prohibiting camping
in certain areas, In addition, race courses have been rehabilitated and access guides have been
published. Some impacts still occur because of the visitor load, but the overall trend is stabilizing.
Response to 28-9
The map for Amendment 9 in the EA includes the Gordon's Well area in the proposed change
from "M" to "L". The map is in error and should have excluded the Gordon's Well area (Sec 31,
T.16S., R.20E., SBM). This correction has been made in the final map.
Response to 28-10
The Gordon's Well area is within the East Mesa ACEC and is a Class "M" area. A Class "I"
open area exists east of Gordon's Well and is not a part of the proposed amendment, but the
area is often referred to as Gordon's Well or East Mesa. The recreation description for
Amendment 9 incorrectly referred to OHV play in the adjacent open area as occurring in East
Mesa. The camping and use on private lands adjacent to the ACEC may have also been referred
to as "OHV play" in East Mesa.
The CDCA Plan permits camping within 300 feet of approved routes of travel. The Southern
East Mesa ACEC and the EAst Mesa wildlife Habitat Management Plan do not limit the area of
camping in Section 31. Inventories found very little evidence of the Rat-tailed Horned Lizard in
this parcel. The camping referred to occurs on or adjacent to an approved route of travel and is
also within the Bureau of Reclamation's withdrawn 2000 foot-wide right-of-way for the Coachella
Canal.
131
Response to Sierra Club, Judith Anderson
Response to 28-11
A variety of factors could affect the flat-tailed horned lizard (FTHL). Monitoring studies are
continuing with the hope of determining the specific causes of both positive and negative effects.
There is little evidence of the presence of the FTHL in the Gordon's Well area, and a trend of
decline within the FTHL habitat for the East Mesa. Therefore, charges that off-road vehicles
are the principal cause of endangering the FTHL in an area where declines have not been proven
is merely speculation.
The CDCA Plan, as amended, is not the only way to protect the habitat of the FTHL. The BLM
is pursuing a variety of approaches in the East Mesa ACEC. On July 27, 1989, important FTHL
habitat on the east side of the ACEC was closed to all camping. The closure removes the main
attraction for recreational use of the East Mesa ACEC and is designed to prevent overflow
camping from extending into important habitat.
Response to 28-12
See responses to 5a- 1, 6-1, 13-2
132
29-1
29
29-2
29-3
PATRICE DAVISON
FIELD REPRESENTATIVE
P.O. Box 2151, Riverside, CA 92516
August 21, 1989
Mr, Gerald Hillier
Manager,
BLM Desert District
1695 Spruce Street
Riverside, Ca.
Re: Comments on proposed 1988 Desert Plan Amendments
Dear Mr. Hillier:
These comments reflect the concerns of the California Association
of Four Wheel Drive Clubs. In general, the Association has great
difficulty accepting proposals for increasing the number of ACECs,
when there is no new outstanding information warranting such
designation.
Comments are referenced by Amendment number:
Amendment 1 - None of the reasons provided are justification for
this additional ACEC. The description accompanying the proposal
clearly points to a lack of adequate consideration of
alternatives. The Bureau's compulsion to automatically designate
an ACEC where potential for controversy or problem exists is an
easy way out that neglects the public and ignores the resource. If
public visitation is a problem, it would seem more appropriate to
stop the current practice (of Barstow BLM personnel) of
intentionally directing people to the area. If one were to
speculate, it would seem as if this was merely an initial step in
the process to close the area to public enjoyment and
appreciation. The case has not been made for this designation, and
the proposal must be rejected.
Amendment 2 - Please refer to the High Desert Multiple Use
Coalition's extensive comments on this matter. Once again, it
would appear that the automatic reaction is to close (via ACEC)
where possible, even when the circumstances do not warrant such.
Amendment 3 - Again refer to HDMUC comments. If this area warrants
ACEC designation, than perhaps the majority of the California
Desert should also be proposed for ACEC status. The case for ACEC
designation must be solid and appropriate.
Amendment 4 - Better definition of paleontolgical values does not
warrant enlargement of this ACEC. Reject this proposal.
Amendments 5,6,7 - Support the deletions.
133
Amendment 8 - Strongly oppose. The existing BLM management efforts
are satisfactory, no proven need to change. Why eliminate what is
working ?
29-4
29-5
29-6
[Ami
Amendment 9 - Strongly oppose because this change will result in
Increased limitations on vehicle access.
29-7
2^8
Amendment 10 - Oppose in part. If Alternative B was proposed,
excluding Mescal and Cinder mine areas, would be acceptable. The
degree of mining in the area suggests that some modification to the
amendment is necessary.
Amendment 11 - In our best judgement. Alternative C is the best
recommendation. The popular area should be enlarged as much as
possible to counteract the restrictive actions occurring
elsewhere. The BLM must provide for the displaced user.
Amendment 12 - Support
Amendment 16 - Strongly oppose the closure to motorized use. The
validity of this area as an ACEC has been questionable from the
start. This proposal is an example of how ACEC designation is used
as a step in the process to close an area to public use. Although
sometimes measured and incremental, the end result is the same.
This area, if closed, would restrict the legitimate access for
other areas as well.
Amendment 17 - Same comment as 16 with the addition that the
question of managability must be examined. ACEC designation should
not mean closure of motorized access. Routes must be available for
public use. Management by closure is a sad commentary on the
Bureau's abilities, and decreases the public confidence.
It is the desire of this Association that the foregoing comments
serve as a means to facilitate some future communication regarding
the proposals. Richard MacPherson is the key contact and can be
reached through my office, or you may call him (714) 682-6924 at
home to set up an appointment.
Thank you very
Plan Amendments.
much for this opportunity to comment on the 1988
Sincerely,
f^^C^^
Patrice Davison
Field Representative
California Association of Four Wheel Drive Clubs
PO Box 2151, Riverside, Ca. 92516
(714) 369-8960
134
Response to Patrice Davison, CA Assn. 4-WD Clubs
Response to 29-1
Cultural resources within the proposed ACEC are listed on the National Register of Historic
Places. Executive Order 11593 requires federal agencies to administer and maintain properties so
that archaeologically significant sites are preserved, restored and maintained (16 U.S.C. 433.2.b.4
1982). The National Historic Preservation Act, Section 10, requires federal agancies to locate,
inventory, and nominate to the Secretary of Interior all properties und
er its control that appear to qualify for inclusion on the National Register and exercise caution
so that historic properties are not allowed to deteriorate significantly.
Cultural resources within the proposed ACEC have been vandalized and subjected to other impacts.
Designation of this area as an ACEC will provide the BLM with the mechanism to give this area
special management to prevent continued impacts. It will also facilitate development of a program
to educate the public in the appreciation and enjoyment of the cultural resources in this area of
the California Desert.
Response to 29-2: See response to 22-1.
Response to 29-3: See response to 22-5.
Response to 29-4
A change in MUC from Class "M" to Class "L" will not increase limitations on vehicle access on
the East Mesa. The vehicle access designation in this area is "limited." Existing routes have
already been designated "open" or "closed" in the route designation process. In addition, the area
of moderate-to-heavy use around Gordon's Well and east of the Old Coachella Canal has been
specifically excluded from the MUC change.
Response to 29-5
The difference between the MUC guidelines for mining in Classes "M" and "L" is that a plan of
operations is required in Class "L" for operation on areas of 5 acres or less. The effect of this
change in the Mescal Range would be negligible, since almost all mining operations are larger
than 5 acres and already require a plan of operations.
Response to 29-6
Alternative C was rejected as it could have negative effects on the Amargosa River and, potentially,
on Death Valley National Monument.
Response to 29-7 and 29-8
Both ACEC plans had previously closed these areas to vehicles. The proposed amendments merely
provide additional documentation of the decision. In addition, neither ACEC contains a designated
route of travel. Consequently, no reduction of authorized 4-WD use will occur.
135
HIGH DESERT MULTIPLE-USE COALITION
P.O. BOX 1167. RIDGECREST. CA 93555
Mr. Gerald E. Hillier
District Manager
California Desert District
Bureau of Land Management
1695 Spruce Street
Riverside. California 92507
August 18, 1939
30
Re: Proposed 1988 Amendments to the 1980 CDCA Plan
Dear Mr. Hillier:
Please consider our comments on the following proposed
amendments ;
1) Rodman Mountains proposed ACEC
30-1
We
supp
designs
tion .
be impl
ement
signing
, cam
mcrea.'i
e use
expend
the e
Rather
than
forth,
the b
who is
allow
return
for f
ort Altern
We are c
ed under t
Pg round de
of the ar
ffort nece
increasing
e.st pro tec
ed by the
unctioning
ative A, that this area deserves ACEC
oncerned that the intensive management to
his Alternative could, however, involve
velopment, etc., which could actually
ea by persons who do not, at this time,
ssary to find areas of such cultural value.
patrols, displaying regulations and so
tion for such resources might be a resident
BLM to live on site on a rent free basis in
as site caretaker and interpreter.
Red Rock Canvon . proposed ACEC
This am
impact on bo
High Desert
area. We no
habit, Sit. We
as in Nightm
in the subje
presence and.
observation
Speci-Etl atte
the uses of
The area is
overgrazing ,
problem" in
Harris, BLM
endment is bei
tany and wildl
Multiple-Use C
ted that the a
.stopped to ob
are Gulch, at
ct area. He w
never left hi
and the subseq
ntion was paid
man and the pr
a part of the
or anything e
the area and m
Range Conserva
ng proposed for its desired positive
ife (p. S-3). Several members of the
oalition (HDMUC) recently visited this
rea is indeed outstanding raptor
serve a great-horned owl perched above
this time the only usable vehicle route
as relatively unconcerned with our
s perch throughout 10 minutes of
uent passage of our three vehicles.
to the effects upon the environment of
ocesses of nature during our visit.
Cantil commom alottment but
Ise livestock-related, is a "non-
ay be confirmed as such by Mr. Glenn
tionist, Ridgecrest Resource Area.
136
30-3
There are nine mining claims in the area, none of which are
active, and, no plans or notices of intent to open new mines have
been filed as of the date of these comments. We could not find
any recent evidence of abuse of resources by prospectors or any
other human visitors and, with the restraints placed upon vehicle
travel by natural barriers and regulatory agency policies, we
found that there is no proliferation, whatsoever, of vehicle
routes .
We also visited the si
a short distance from Night
cannot be found except by o
foot trail, where it exists
is steep and slippery in pi
20 feet across its widest d
represent anything recogniz
because of its rarity in th
compared to other Southwest
particular danger and is no
at this time other than tha
intentional omission of any
managing agencies.
te of the geoglyph or intaglio. It is
mare Gulch but the hiking route to it
ne who already knows the way. The
, is only barely visible and the way
aces. The intaglio is small, perhaps
imension, and does not obviously
able. While somewhat significant
e locale, it is not impressive when
desert sites. We believe it is in no
t deserving of any special protection
t which would be afforded by an
publicity efforts on the part of the
30-2
It is unclear to us why this area needs ACEC designation.
The Nightmare Gulch route is already closed to all human
visitation from February 1 to July 1 each year for the protection
of raptors during their nesting season. The timing of this
closure also benefits desert tortoises, who are most active
outside their burrows from March 1 through June 30, according to
Desert Tortoise Natural Area literature. The Nightmare Gulch-
Black Rock Canyon Loop is the only passable route through the
area at present. As a note, the map of this area in the back of
the Proposed Amendments book doesn't show this complete route but
it does show routes that are impassable and effectively no longer
exist. The Loop route is additionally closed to vehicles for
one-half of each of the other --even months of the year (open only
for non-motorized travel duri^i Lne other half of each of those
jraonths ) .
While it is stated on page 3-2 that the nojave ground
squirrel may occur in portions of this area, this has not been
positively documented. As for endangered plants, the only
serious danger here is from the "scouring" effects of heavy,
localized rainfall. Such runoff frequently makes dramatic
changes to features in the canyon bottoms but the native plants
evolved under these conditions. By the way, when repairs to the
abovementioned Loop are necessary to maintain passability from
one year to the next, this maintenance is performed by the
Geargrinders 4WD Club of Ridgecrest via a Cooperative Management
Agreement (CMA) between themselves, the ELM and State Parks,
signed 3/22/85. The cost to the public for this, being only for
the required supplies and materials, is minimal. We understand
that the ELM is able to gain additional funds for the management
of an area if the area can be declared an ACEC. We don't believe
137
that this is ethical, however, unless the environmental concerns
of an area can stand on their own merits, i.e. , simply saying
that an area needs more protection does not make it so.
In summary, we find nothing deserving "critical concern" in
this area, we believe this amendment is unnecessary and, we urge
you to reject it (Alternative B) .
30-4
30-5
30-6
3) Dedeckera Canvon (Eureka-Saline Corridor), proposed ACEC
This amendment looks like a prelude to some kind of closure
of the public road through this area which is most widely known
as the Eureka-Saline Corridor. This is the only road in the area
and the only vehicular route between the Eureka and Saline
Valleys. From page 4-3 of the Proposed Amendments, we quote,
"the open route could be a potential threat to adjacent
resources." And, "any proliferation of the Eureka-Saline
Corridor or irresponsible activities by users of the route could
have detrimental effects on sensitive plant species in the
amendment area." However, on page 3-4, it is stated, "Very
little, if any, trail proliferation has occured." Apparently,
protection for the sensitive plant species July gold is the only
reason this amendment is being proposed.
These questions come to mind: In an area as undeveloped and
far-removed from population centers as this, does the sensitive
plant species July gold not have adequate habitat in many other
_canyons in the Last Chance Range to assure its healthy survival?
How would "the activities of users of the Eureka-Saline Corridor"
be controlled if the road is to remain open (p 4-4)? Since it is
openly acknowledged that no proliferation of roads or trails has
occured up until now, and there are no obvious indications that
proliferation is about to occur, why make this area an ACEC?
Similar logic would ban all off-highway driving anywhere in the
desert for fear that someone might someday abuse resources.
We believe that a Sierra Club group drove through the
Corridor within the past year, camping out, hiking to the top of
various desert peaks and generally looking for evidence of human
abuse. They pronounced the area to be essentially free of same.
Cultural resources in the area remain uninventoried and it would
seem to be reverse logic to declare an area an ACEC so that an
inventory could be facilitated so that something might be found
that would justify the area's ACEC designation. It is stated
that ACEC designation would not impact wildlife.
The necessity of an ACEC designation for this area has not
been adequately demonstrated. We urge the rejection of this
amendment (Alternative B) now and until such time as an increase
in use (and abuse) of this area is self-evident.
138
11) Dumont Dunes Usage Designation Changes
We support Alternative B, the BLM-pref erred alternative.
Addit iona 1 comments
The Gear Grinders 4WD Club of Ridgecrest, an affiliate of
the High Desert Multiple-Use Coalition, maintains the passability
of three off -highway routes of travel in the California desert.
Their efforts are acknowledged by the ELM to be valid volunteer
public lands work. Two of those routes are in the areas that
would be affected by Amendments 2 and 3. We hope that the CDCA
amendment process does not become a vehicle for the carrying out
of personal vendettas against either the Gear Grinders Club or
individual members of that club.
Thank you for allowing us to participate in the amendment
process and for your consideration of our comments on the
Proposed 1988 CDCA Plan Amendments.
Sincerely, for the membership_of the High Desert
Multiple-Use Coalition,
Co-Chairman
Copies to:
-California State ELM Director Ed Hastey
-California Desert Coalition
139
Response to High Desert Multiple-Use Coalition
Response to 30-1
Management of the ACEC will involve signing, surveying, monitoring, patrol, enforcement, and if
necessary, data recovery. The preservation and protection of cultural resources will be given the
highest priority. No campground is planned, and specific identification of cultural sites will be
avoided.
Response to 30-2
See response to 22-1.
Response to 30-3
See response to 26-1.
Response to 30-4
See responses to 14-2, 22-3, 22-4.
Response to 30-5
Although other small populations of Dedeckera eurekensis have been found in this region, the
range is so small that each population needs protection.
Response to 30-6
See response to 22-5.
140
SSi=Ao3
Buereau of Land Managemen t" - f A - ^fr
California Desert District
Attn: Mr Gerald Hillier, Di;S;tirlQt?*lai!iMg2^r27
1695 Spruce Street
Riversidet CA 92507 C . . . -.-Jr.; = JJIi^iCT
August 21, 1989
31
Dear Mr. Hi 1 i lert
I appreciate this opportunity to submit comments regarding
"Proposed 1988 Plan Amendments to the California De'
Conservation Area Plan of 1980"» Please add my name to
distribution list concerning future proposed amendments, records
of decision or any similar material open for public input.
Amendment 1* New ACEC at Rodman Mountains Cultural Area
31-1
On page 2
Subm 1 ss 1 o
special m
designati
designat i
without
substant i
I support
signing s
patrol s c
plan can
the use o
pamph lets
appropria
-2f under
n" f it IS
anagement
on. How
on general
p er man en t
ally unnot
alter nat i
hou 1 d be d
an be unde
be imp 1 e
f pamph let
could
te Resourc
the column entitled, "Proponent's Reason for
stated that the ACEC designition would provide
over and above that provided by a wilderness
will this be accomplished since a wilderness
ly refers to those areas untrammeled by man,
improvements or the imprint of man's work is
iceab 1 e''
ve A, accepting this amendment. However, no
one until sufficient monitoring and enforcement
rtaken. Until the complete ACEC management
mented, education could be accomplished through
s containing interpretive information. These
be made available upon request from the
e Area Off ices.
31-2
Amendment 2S New ACEC Adjacent to Red Rock Canyon
This proposed ACEC is already regulated by numerous overlapping
management tools. Last year's plan amendments changed the
proposed ACEC area to Class L. Approximately 90% of the proposed
ACEC IS already covered by the raptor seasonal (Closure from
February 1 to July 1 annually. The Memorandum of Understanding
(MOU) with Red Rock Canyon State Park (RRCSP) and the BLM allows
vehicle access in the proposed ACEC only from the 16th of each
month to the end of each month. These multiple layers of control
result in eliminating all public entry to 90% of the proposed ACEC
for 150 days per year, while vehicle access to this same area is
not allowed on 255 days out of the year.
Wildlife concerns mentioned that were not specifically addres
by the closure and MOU, are the desert tortoise and the Moj
ground squirrel.
ssed
ave
Page 1
141
According to the BLM brochure entitled "Desert Tortoise Natural
Area"t the statement is made^ "From mid-June through February^
most tortoises are usually deep in their burrows and are seldom
seen." Additionally, the draft management plan for the Crucial
Desert Tortoise Habitat in Fremont Valley and Surrounding Areas,
April 89, suggests under management r ecomendat ions, Sec.
111(D)(3)(a) designating a seasonal competitive and permitted ORV
event closure during tortoise emergence (March 1 to June 30).
Therefore, under the current area management, protection is
already afforded the desert tortoise by the raptor seasonal
closure dates and the additional vehicle restrictions under the
MOU.
31-3
The statement that the Mojave ground squirrel may occur in
portions of the affected area, indicates that there is
insufficient data to raise it as an issue. However, the same
protection that the desert tortoise enjoys from humans and
vehicles applies to the Mojave ground squirrel. Unfortunately for
the Mojave ground squirrel, there isn't any protection from the
nesting raptors looking to feed their young.
Addressing the sensitive and listed plant concerns. Grazing
animals and mineral exploration would definitely pose a threat to
these plants and needs to be addressed. The Red Rock tarweed that
grows in the moist canyon bottoms, is protected from human and
vehicle impacts for part of winter, through spring and into
summer. Seasonal run-off rearranges these canyon bottoms
extensively in this area, sometimes taking it down to the
underlying rock. This must have an even greater negative impact
on these relicit plants than do man and vehicles.
ated that there are four
posed ACEC, I assume
ccompanying map with the
ess Guide #7, printed Se
awbone/Dove Springs Dese
two routes. The Red Roc
two routes. I went d
ound there are only
sed ACEC, one through Bl
ugh part of Nightmare
ut of the gulch as EP-12
ce has incorrectly bl
he Nightmare Gulch route
notify them of this
e opened. Upon acquirin
ement Agreements (CMA)
e was a CMA between the
(GG). This CMA states
or keeping the the appro
Nightmare Gulch' loop ro
also states that the
s current primitive cond
Is are to be used. Thi
e proposal. Incidentall
ciety CMA (for entering
Page 2
des ignate
these are
proposal .
pt. 1988
rt Access
k Canyon
own and ma
two des ig
ackrock Ca
Gu Ich,
0. If for
ocked off
isn't sho
fact so
g copies o
concerni ng
BLM, RRCSP
that th
ximateiy 6
ad passabl
route wou
1 1 1 on Wit
s CMA was
y, the map
the area d
d OHV
the
The
shows
Gu i de
State
de an
nat ed
nyon,
route
some
the
wn on
the
f the
the
, and
e GG
mile
e for
Id be
h no
nev er
that
ur 1 ng
142
ylthe seasonal closure to monitor nesting birds and sensitive
plants) IS excellent. I wish their CMA map had accompanied the
proposal since they are the proponents of this amendment.
The archeological site record, CA-KER-244, 12/87, for the
geoglyph/i ntagl lo in question states that the Park rangers were
mainly concerned that the intaglio might be altered by Geology
field class pedestrian traffic. This intaglio is not visible from
the vehicle route, and requires a slippery, sandstone climb to
reach. Its actual location not being well known to the general
public protects it from the casual visitor.
Summarizing, I support alternative A, accepting this amendment, to
protect the area from grazing pressures and mineral exploration.
However, I would suggest adjusting the ACEC boundary to coincide
with the annual seasonal closure boundary since it is easily
identified and will provide an open route to the area north of the
proposed ACEC area. No additional vehicle/human use closures or
route restrictions should be added since the existing management
restrictions are completely sufficient.
31-4
Amendment 3* New ACEC at Dedeckera Canyon
First of all, I wasn't able to find Dedeckera Canyon on any of my
USGS maps, BLM maps, AAA maps, DeLorme Atlas Gazetteer, etc. Next
time, please put some common name, le. Eureka Valley Dunes in
paranthesis somewhere in the name. This naming convention would
allow the relative location of the amendment area to be easily
identified within the CDCA
31-5
On pag
Submi s
ACEC p
Dedeck
1 1 sta
the pi
page 3
that
the he
tra i 1
plant
concer
straig
propos
wi thou
e 2-2, und
sion " , it
rov 1 de hab
era eureke
tes that t
ant's hab 1
-4 the rou
IS bordere
ad 1 ng of r
prolifera
species Ju
n for Ju
ht- line di
ed ACEC
t vehicle
er th
is st
1 tats
nsi s.
he Eu
tat.
te IS
d by
ecr ea
t ion
ly go
ly go
stanc
of J
acces
e CO
ated
for
On
r eka
I a
des
stee
t ion
has
Id i
Id 1
e f r
ust
s to
1 umn
tha
un i
pag
-Sal
ssum
crib
P
t
s
s
om
ca
it
oc
mi
r e
t
ove
the
ent 1
t the
que p
e 4-3
1 ne C
e thi
ed as
ny on
IS s
cur re
n imal
su 1 1 1
he Eu
r two
cor r
tied
dol
lant
, un
or r 1
s ac
gen
wail
tate
dt
fro
ng f
r eka
mil
1 dor
, "Pro
omi te c
assemb
der wi 1
dor pas
tuai ly
e ra 1 1 y
s. Aga
d that
ther ef o
m vehic
r om h ik
Dunes
es will
ponent
liffs
lages,
dlif e
ses d 1
means
follow
in on
very 1
re th
les.
ers, t
picnic
be a
's R
of th
1 nc 1
and V
recti
be low
i ng a
page
ittle
e imp
If ho
hen a
are
probl
eason
e prop
ud i ng
ege tat
y thr
, sine
dry
3-4, u
f if
act to
we ver ,
pprox 1
a to
em wit
for
osed
the
ion,
ough
e on
wash
nd er
any
the
the
mate
the
h or
On page 4-3 it is stated that the open route could be a potential
threat to adjacent resources. In what regard does a single, route
threaten the adjacent resources since little or no trail
proliferation has occurred. On the other hand, the route provides
access to the wildlife guzzler for periodic maintenance.
I support alternative B, reject the amendment. This amendment is
unnecessary since the proposed ACEC is already closed to vehicular
access (except for the one route F-1794, covered under a CMA to be
Page 3
143
ma 1 n ta i ned
managed as
as a
Class
primitive
L under
4WD
the
route)t and is currently being
managea as uiass l unaer T^ne Interim Management. Policy and
Guidlines (IMP)* Vehicular or human use in the canyon hasn't been
shown to be a significant problem*
31-6
If it should be decided to accept alternative Af I strongly urge
that the corridor remain open* Its primitive nature^ the long
summer heat and the remoteness of the location all effectively
control the human use of the corridor for nearly half of the year*
31-7
Amendment 48 Enlarge Coyote Mountains ACEC (No. b,2)
This amendment seems unnecessary since the ACEC is currently
managed Class L, is closed to OHV use> and lies within a WSA
recommended nonsuitable for wilderness designation* However^ if
it IS felt that the ACEC is necessary for protection of the fossil
resourcet then I support alternative At accept the amendment^ with
one suggestion for the amendment plan* Please set aside a
reasonable size area, designated for hobby fossil collecting.
Amendments 5^ bf 7! Deletion of ACECs (No* 28, 38 and 51)
I support alternatives A, accept all of these amendments.
Amendments 8 9*
31-8
changing specified area
"M" to "L"
Class designation from
I suport alternatives A, accept amendment in both cases for the
specific purpose of preventing the lands from being used for
disposal sights, as well as protecting the mentioned cultural
resources* However, I suggest that as stated in both amendment
environmental consequence sections, that the changes in multiple
use class should have little negative effect on current recreation
uses*
Amendment lOS
Change Class "M" areas to Class
Mojave Scenic Area
"L"
in
the East
I support alternative A, accept amendment* The Mojave Road and
the East Mojave Heritage Trail should be protected from stated
few road closures mentioned in the Environmental Consequences
section* Also, care must be taken when making the Class L
boundaries so as not to include probable rare earth deposits*
Page 4
144
Amtndmant lit Change to Class "I" and Vehicle Access to "Open"
for Area Adjacent to Dumont Dunes OHV Area
I support alternative A, accept amendment.
Amendinent 12* Change Portion of Ivanpah Lake from Class "L"
to Class "M"
I support alternative B^ reject amendment.
Amendment 13f 14» 152 Eliminate Utility Corridors and Portions
of Cor r 1 dors.
I support alternatives Af accept all these amendmentst with the
following st ipu lat ions J
Regarding amendment 14^ maintain the Mojave Road where it
currently exists.
Regarding amendment 15» include the segments of the corridor road
as proposed to the East Mojave Heritage Trail. However^ formal
maintenance the road would no longer be necessary, and could be
handled under a CMA.
31-9
Amendment 16 17S Change Vehicle Access from "Limited" to
"Closed" in ACEC areas (No. 57 55)
I support alternatives At accept amendments. However, I don't
understand the necessity of this vehicle access change, since the
applicable ACEC plans previously closed the same areas to
motorized vehicles.
Amendment 18* Prohibit grazing South of I nterstate- 10 in the Ford
Dry Lake Allotment
I support alternative A, accept amendment.
Amendment 19X New Ephemeral Grazing Allotment Near Daggett
I support alternative C, reject amendment.
Again, thank you for this opportunity to comment concerning these
ammendme n ts.
Page 5
145
Sincerely
Wayn e Re 1 1 ig
/^LJLofjLfoiJit , C A 93SJSS
Response to Wayne Rettig
Response to 31-1
A cultural ACEC is specifically managed for its cultural values as compatible with wilderness values
and could have more stringent management than a wilderness area.
Response to 31-2
See response to 22-1.
Response to 31-3
See response to 22-2.
Response to 31-4
The Plan Index Map (p. 1-2 in the E.A.) gives the general location of each amendment proposal.
The map for Amendment Three in the Appendix shows that Dedeckera Canyon is close to the
Eureka Dunes and at the north end of the Eureka/Saline Corridor (Route F-1794). The Canyon
has been labeled on the final map in this document.
Response to 31-5
See response to 22-5.
Response to 31-6
See response to 14-2 and 22-3.
Response to 31-7
Fossil Canyon or Alverson Canyon, located at the southern end of the Coyote Mountains, is still
available for fossil collection.
Response to 31-8
The class change will not have an appreciable effect on recreation use within either area.
Response to 31-9
See response to 29-7 and 29-8.
146
^€t^A 03Z
THE CAIIFORNIA NATIVE PIANT SOCIETY
DEDICATED TO THE PRESERVATION OF CALIFORNIA NATIVE FLORA
24001 Martin Road
Carmel Valley, CA 93924
August 19, 1989
California Desert Office, BLM
1695 Spruce Street
Riverside, CA 92507
ATTN
Plan Amendments
32
Gentlemen ,
The California Native Plant Society supports all 19 of the
proposed amendments to the Desert Plan. We especially give
strong support to Amendment No. 4 which would make Dedeckera
Canyon an Area of Critical Environmental Concern (ACEC).
Dede
plan
whic
extr
dolo
ther
Even
Stan
is a
Dede
The
part
here
cker
ts,
h ha
emel
mite
e wo
wit
d up
Irea
cker
pres
ial
a Cany
mostly
ve not
y rare
cliff
uld be
hout c
to in
dy sta
a Cany
ent de
protec
on IS
ende
yet
Dede
a t
mics
been
cker
reasu
Th
inve
a eur
re t
ere
stig
eken
rove o
are al
ated .
sis ( "
s , wo
noth
a m p f i
nocen
te-li
on ma
signa
tion
uld
ing
res
t re
sted
y he
tion
for
be a
but r
the f
creat
as r
Ip pr
of W
the u
temp
are
ragi
iona
are ,
even
ilde
niqu
ting p
shrubs
le veg
1 impa
and i
t a ne
rness
e na tu
f rare
so arc
The t
July G
lace t
to bu
etatio
ct . D
ncreas
ed for
Study
ral he
and rel
haeologi
ype loca
old"), s
o camp .
rn for c
n cannot
edeckera
ed prote
federal
Area pro
ritage r
ati ve
cal s
lity
urrou
Howe
ampf i
for
eure
ly rare
ites
of the
nded by
ver ,
res .
long
kensis
ction
list
vides
epres
m
ing .
only
ented
Dedeckera Canyon is worthy of ACEC status if any place ever was
Thank you for your consideration.
.. r
CO
" t:
Osl
,""•. f
€V>
■: 1. ■
3!:
O'S
'"l-
CO
■ -t.
OJ
■. rO
J 1 '
f.»
■■■JS
»
•<c
..-.1
.;>-j
♦4.,";
' -s
—
Sp.ncerely , / i ;
// Ml
Suaaniie Schejttler
Presijoent
147
APPENDICES
APPENDIX A
-RESPONSE TO U. S.D.I,, BUREAU OF RECLAMATION
IJnited States Depaitment of the Interior
BUREAU OF LAND MANAGEMENT
CALIFORNiA DESERT DISTRICT
1695 Spruce Street
Riverside, California 92507
TAXE
PIdDEIN,
AMERICA
IN RFPLY REFER TO:
1600
CA-067.21 )
Memorandum
To :
Regional Environmental Officer, Bureau of Reclamation, Lower
Colorado Regional Office, P. O. Box 427, Boulder City, Nv
89005
From
Subject
District Manager, California Desert
Proposed 1988 Plan Amendments/Class Change in the East
Mesa, Imperial County
The change from Class M to Class L, in and of itself, will not affect your
proposed recharge project in the East Mesa. An environmental assessment of
the proposed project would be required in either Class. However, the Class L
designation highlights the potential resource conflicts and insures higher
management priority and attention.
The proposed Class L designation will more accurately portray potential resource
conflicts in East Mesa. Since implementation of the Desert Plan a large amount
of new inventories have been conducted to determine the extent of wildlife and
cultural resources in the area. The results indicate that these resources occur
over a larger area, and in greater density than originally thought.
There are four wildlife species of special management concern known to occur in
the East Mesa: the Flat-tailed horned lizard, the Colorado Desert fringe-toed
lizard, the Yuma clapper rail, and the California black rail.
The Yuma clapper rail is a State threatened and Federally-listed endangered
species. The Flat-tailed horned lizard is a BLM sensitive species and was
recently upgraded from a Category 2 to a Category I candidate for listing by
U. S. Fish and Wildlife Service as threatened or endangered. We have enclosed
a copy of our recent status report for this species. The California black rail
and the Colorado Desert fringe-toed lizard are Category 2 candidates for U. S.
Fish and Wildlife Service listing.
— lake. fixLaa in uoui (^aLLjoxnia -L^£i.£xt (^oniEiuation cTTXEa . .
cyy cyVatLonaL _'T£aiaT£.
The western portion of East Mesa coincides with the relict shoreline of Lal<e
Cahuilla. The archaeological site densities now found there is nearly
unparalleled in the California Desert.
Several special management designations exist within the East Mesa area because
of these resource values.' There are four archaeological Areas of Critical
Environmental Concern (ACEC) and one large ACEC designated for wildlife
values. In addition there is a Habitat Management Plan which has been prepared
for the southern East Mesa area. Copies of these documents were sent to your
office for review.
The Class L designation is more compatible with the identified resource sensi-
tivity, and will allow a higher degree of control, and therefore protection, to
both the cultural and wildlife resource values. Future environmental assess-
ments for recharge projects should consider all reasonable alternatives, includ-
ing pumping rather than creating spreading basins.
APPENDIX B
AMENDMENTS NOT CONSIDERED
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